U.S. DEPARTMENT 

OF AGRICULTURE

Workforce Decisions 

Could Benefit from

Better Linkage to 

Missions and Use of 

Leading Practices

Report to the Chairwoman, Committee 

on Agriculture, Nutrition and Forestry, 

U.S. Senate

March 2014

GAO-14-288

United States Government Accountability Office
United States Government Accountability Office

Highlights of GAO-14-288, a report to the 

Chairwoman, Committee on Agriculture, 

Nutrition and Forestry, U.S. Senate

March 2014

U.S. DEPARTMENT OF AGRICULTURE

Workforce Decisions Could Benefit from Better 

Linkage to Missions and Use of Leading Practices

Why GAO Did This Study

FSA, NRCS, and RD, USDA’s service 

center agencies, interact directly with 

agricultural producers and rural 

communities through extensive field 

office structures. Achieving their 

missions depends in part on sustaining 

workforces with the necessary 

knowledge and skills. In fiscal year 

2012, FSA, NRCS, and RD closed field 

offices and offered buyout and early 

retirement incentives to employees. 

GAO was asked to review aspects of 

USDA’s human capital management. 

This report examines: (1) how the 

workforces of USDA’s service center 

agencies changed from fiscal year 

2003 to fiscal year 2012, (2) the extent 

to which USDA’s policy on supervisory 

ratios aligned with OPM guidance in 

fiscal year 2012, and (3) the extent to 

which USDA’s service center agencies 

followed leading practices when 

closing offices and reducing staff in 

fiscal year 2012. GAO analyzed 

workforce data from OPM and USDA, 

reviewed documents, interviewed 

relevant officials, and compared 

leading practices with the actions 

agencies took to close offices and 

reduce staff in fiscal year 2012.

What GAO Recommends

GAO recommends, among other 

things, that USDA take actions to 

revise its supervisory ratios policy; 

amend its policy on organizational 

changes to follow leading practices; 

and require RD and FSA to document 

links between various incentives and 

reshaping or strategic goals. USDA 

generally agreed with GAO’s findings 

but disagreed with one finding and 

recommendation on supervisory ratios. 

GAO continues to believe in the need 

for a revised supervisory ratios policy.

What GAO Found

From fiscal years 2003 to 2012, the size of the workforces declined at the U.S. 

Department of Agriculture’s (USDA) service center agencies—the Farm Service 

Agency (FSA), Natural Resources Conservation Service (NRCS), and Rural 

Development (RD). The size of USDA’s service center agencies declined by a 

higher percentage from fiscal years 2011 to 2012 than the average annual 

percent decline from fiscal years 2003 to 2012 (see fig.). 

Declines in the Size of USDA’s Service Center Agencies’ Workforces 

In fiscal year 2012, USDA policy on supervisory ratios did not align with Office of 

Personnel Management (OPM) guidance that states that an analytical approach 

can help agencies achieve the right balance of supervisory and nonsupervisory 

positions to support their missions. Instead, USDA’s policy stated that all its 

agencies, regardless of their missions, should aim for a target ratio of one 

supervisor for at least nine employees (1:9). USDA officials were not able to 

provide a documented basis for this target ratio. In addition, USDA did not ensure 

that the service center agencies calculated their supervisory ratios the same way. 

As a result, USDA did not receive comparable information on supervisory ratios.

In fiscal year 2012, USDA’s service center agencies generally followed or 

partially followed leading practices that GAO has identified when closing offices 

and using buyout and early retirement incentives as follows:

• In closing offices, NRCS fully followed, and FSA and RD partially followed, 

the practice to present a business-case or cost-benefit analysis. USDA’s 

policy on organizational changes did not direct agencies to follow leading 

practices to demonstrate to stakeholders they considered information such 

as underlying assumptions and other alternatives. 

• In using buyout and early retirement incentives, all three agencies fully 

followed practices to identify reshaping goals and to develop strategies that 

consider alternatives. However, NRCS followed, FSA partially followed, and 

RD did not follow the practice to link incentives to workforce reshaping or 

overall strategic goals. FSA and RD did not have human capital or workforce 

plans to clearly document how these strategies linked with broader efforts 

and could not show whether their remaining workforces had the right balance 

of skills in the right locations to support their missions.

View GAO-14-288. For more information, 

contact Anne-Marie Fennell at (202) 512-3841 

or fennella@gao.gov.
Page i GAO-14-288 Department of Agriculture

Letter 1 

Background 4

Size of the Workforces of USDA Service Center Agencies 

Decreased, but Other Workforce Characteristics Largely 

Remained Constant 11

USDA’s Policy on Supervisory Ratios Did Not Align with OPM 

Guidance in Fiscal Year 2012 19

USDA’s Service Center Agencies Generally or Partially Followed 

Leading Practices When Closing Offices and Reducing Staff in 

Fiscal Year 2012 20

Conclusions 34

Recommendations for Executive Action 36

Agency Comments and Our Evaluation 36

Appendix I Objectives, Scope, and Methodology 39

Appendix II Additional Information on the Workforces of USDA’s Service Center 

Agencies in Fiscal Year 2012 45

Appendix III Section 14212(b) of the Food, Conservation, and Energy Act of 2008 

and the Farm Service Agency’s Office Closures Initiated in Fiscal 

Year 2012 54

Appendix IV Comments from the Department of Agriculture 57

Appendix V GAO Contact and Staff Acknowledgments 59

Tables

Table 1: Changes in the Size of the Workforces of USDA’s 

Service Center Agencies by Location and Type of 

Appointment 14

Contents
Page ii GAO-14-288 Department of Agriculture

Table 2: The Farm Service Agency’s (FSA) Mission-Critical 

Occupations’ Series, Titles, and Examples from Position 

Descriptions 48

Table 3: The Natural Resources Conservation Service’s (NRCS) 

Mission-Critical Occupations’ Series, Titles, and Examples 

from Position Descriptions 49

Table 4: Rural Development’s (RD) Mission-Critical Occupations’ 

Series, Titles, and Examples from Position Descriptions 50

Figures

Figure 1: Size of the Workforces of USDA’s Service Center 

Agencies from Fiscal Years 2003 to 2012 12

Figure 2: Declines in the Size of USDA’s Service Center Agencies’ 

Workforces 13

Figure 3: Supervisor-to-Employee Ratios of the Workforces of 

USDA’s Service Center Agencies in Fiscal Years 2003 

and 2012 16

Figure 4: Changes in the Occupational Composition of USDA’s 

Service Center Agencies from Fiscal Years 2003 to 2012 18

Figure 5: Extent to Which USDA’s Service Center Agencies 

Followed Leading Practices for Successful Office 

Closures 21

Figure 6: Extent to Which USDA’s Service Center Agencies 

Followed Leading Practices for Using Buyout and Early 

Retirement Incentives 29

Figure 7: Ethnicity and Race of the Career Permanent Workforces 

of USDA’s Service Center Agencies by Location in Fiscal 

Year 2012 46

Figure 8: Grades of the Career Permanent Workforces of USDA’s 

Service Center Agencies by Location in Fiscal Year 2012 47

Figure 9: Percentage of the Career Permanent Workforces of 

USDA’s Service Center Agencies in Length of Federal 

Service Categories in Fiscal Year 2012 52

Figure 10: Percentage of the Career Permanent Workforces of 

USDA’s Service Center Agencies Eligible to Retire in 

Fiscal Year 2012 and Those Projected to Become 

Eligible for Retirement in the Next 5 Years 53
Page iii GAO-14-288 Department of Agriculture

Abbreviations

FSA Farm Service Agency

MCO mission-critical occupation

NRCS Natural Resources Conservation Service

OPM Office of Personnel Management

RD Rural Development

SED state executive director

SL Senior Level

USDA U.S. Department of Agriculture

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Page 1 GAO-14-288 Department of Agriculture

441 G St. N.W.

Washington, DC 20548

March 31, 2014

The Honorable Debbie Stabenow

Chairwoman

Committee on Agriculture, Nutrition and Forestry

United States Senate

Dear Madam Chairwoman:

The ability of the U. S. Department of Agriculture (USDA) to achieve its 

mission depends in part on sustaining a workforce with the necessary 

knowledge and skills. According to the Secretary of Agriculture, the 

department has faced reductions in discretionary spending of about $3 

billion (or 12 percent) from fiscal years 2010 to 2012. To implement these 

reductions, USDA and its agencies have taken various actions to 

restructure operations and reduce their staffs, including through closing 

offices and offering buyout and early retirement incentives.

In fiscal year 2012, USDA announced that eight agencies would close 

offices and programs. Of these, the three agencies with the largest overall 

staffing level percentage reductions were USDA’s service center 

agencies—the Farm Service Agency (FSA), Natural Resources 

Conservation Service (NRCS), and Rural Development (RD).1 These 

agencies interact directly with agricultural producers and rural 

communities through an extensive field office structure.

In its 2012 annual report, USDA’s Office of Inspector General said the 

need to plan for reduced staff in certain USDA agencies is one of the 

department’s most serious management challenges.2 Specifically, the 

report noted that USDA needs to ensure that, even as it reduces staff in 

certain agencies, it maintains its ability to accomplish mission-critical 

functions such as the servicing and oversight of billions of dollars in loans, 

which are handled by USDA’s service center agencies. The Office of 

 

1

Staffing levels refer to the full-time equivalent data presented in agency budget 

documents. Full-time equivalent refers to the total number of regular straight-time (i.e., not 

including overtime or holiday hours) worked by employees divided by the number of 

compensable hours applicable to each fiscal year.

2

USDA, Office of Inspector General, USDA Management Challenges (Washington, D.C.: 

Aug. 10, 2012).
 

Page 2 GAO-14-288 Department of Agriculture

Inspector General in its 2013 update on the department’s management 

challenges stated that USDA should appropriately train and utilize its staff 

in the face of significant staff reductions.3

Having information on human capital trends over time such as changes in 

staffing levels and shifts in occupation types can be helpful in 

understanding the impact of such changes on the workforce and on an 

agency’s ability to achieve its mission. For example, in a 2012 survey, 

federal chief human capital officers noted the importance of using 

workforce analytics to examine agency data and the need for data 

analytics to be used as a predictive tool, particularly in the areas of 

retirement and succession planning.4 In addition, we previously reported 

that federal agencies experienced significant challenges to deploying the 

right skills, in the right places, at the right time, in the wake of extensive 

downsizing during the early 1990s, which was done largely without 

sufficient consideration of the strategic consequences.5

You asked us to review aspects of USDA’s human capital management 

related to office closures and staff reduction efforts in fiscal year 2012. 

This report examines: (1) how the workforces of USDA’s service center 

agencies changed from fiscal year 2003 to fiscal year 2012, (2) the extent 

to which USDA’s policy on supervisory ratios aligned with Office of 

Personnel Management (OPM) guidance in fiscal year 2012, and (3) the 

extent to which USDA’s service center agencies followed leading 

practices when closing offices and reducing staff in fiscal year 2012.

To determine how the workforces of USDA’s service center agencies 

changed from fiscal year 2003 to fiscal year 2012, we analyzed workforce 

data from the OPM’s Enterprise Human Resources Integration database 

and USDA’s National Finance Center; reviewed available reports, plans, 

and departmental guidance from OPM and USDA related to human 

 

3

USDA, Office of Inspector General, USDA Management Challenges (Washington, D.C.: 

Aug. 13, 2013).

4

Partnership for Public Service, Bracing for Change: Chief Human Capital Officers Rethink 

Business as Usual (Washington, D.C.: August 2012). 

5

GAO, Human Capital: Key Principles for Effective Strategic Workforce Planning, 

GAO-04-39 (Washington, D.C.: Dec. 11, 2003). 
 

Page 3 GAO-14-288 Department of Agriculture

capital management; and interviewed OPM and USDA officials.6 We took 

several steps to ensure the reliability of the data and analytical process. 

We chose to report workforce data for 10 years, starting in fiscal year 

2003, because this period provided a historical context for the changes 

that occurred in fiscal year 2012, among other things. Most of our 

workforce data are reported for career permanent employees on full- or 

part-time schedules because they represent a more stable part of the 

workforce.

To determine the extent to which USDA’s policy on supervisory ratios 

aligned with OPM guidance in fiscal year 2012, we reviewed OPM 

guidance on its Human Capital Assessment and Accountability 

Framework and compared it with USDA’s policy on supervisory ratios; 

analyzed workforce data from OPM and USDA databases on supervisory 

ratios; reviewed reports from USDA’s service center agencies on their 

supervisory ratios and compared them with USDA guidance on 

calculating supervisory ratios, as well as standards for internal control in 

the federal government; and interviewed officials from OPM, USDA, and 

USDA’s service center agencies.

To determine the extent to which USDA’s service center agencies 

followed leading practices when closing offices and reducing staff, we 

reviewed leading practices identified previously by GAO for successful 

consolidations such as office closures and examined provisions in the 

Food, Conservation, and Energy Act of 2008 (2008 Farm Bill) applicable 

to FSA’s office closures.7 We did not assess whether FSA complied with 

the 2008 Farm Bill’s office closure provisions. In addition, we reviewed 

provisions in the Chief Human Capital Officers Act of 2002 revising the 

use of voluntary early retirement authority and voluntary separation 

incentive payments, which are referred to in this report as buyout and 

early retirement incentives. We also reviewed regulations and guidance 

from OPM on the use of buyout and early retirement incentives and 

leading practices from previous GAO work on consolidating physical 

 

6

Data from the Enterprise Human Resources Integration database generally represent a 

snapshot of employees onboard as of September 30 in each fiscal year.

7

Pub. L. No. 110-246, tit. XIV, § 14212 (2008).
 

Page 4 GAO-14-288 Department of Agriculture

infrastructure and using buyout and early retirement incentives.8 For both 

office closures and staffing reductions, we reviewed standards for internal 

control in the federal government. We compared these criteria with 

information provided by USDA’s service center agencies about the 

actions they took to close offices and reduce staff in fiscal year 2012. We 

also interviewed officials from the three agencies and representatives of 

employee associations and unions to gather additional information about 

the effects of office closures and staff reductions on agency operations. 

Appendix I presents a more detailed description of our objectives, scope, 

and methodology.

We conducted this performance audit from October 2012 to March 2014, 

in accordance with generally accepted government auditing standards. 

Those standards require that we plan and perform the audit to obtain 

sufficient, appropriate evidence to provide a reasonable basis for our 

findings and conclusions based on our audit objectives. We believe that 

the evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objectives.

USDA is one of the largest civilian federal government departments, with 

more than 100,000 employees as of the end of fiscal year 2012. It is 

composed of 17 agencies and a number of departmental offices. FSA, 

NRCS, and RD are collectively referred to as USDA’s service center 

agencies. They provide financial and technical assistance to agricultural 

producers and rural communities. Specifically, FSA provides payments 

and loans to agricultural producers through various programs, including 

farm commodity and crop disaster assistance programs authorized in the 

2008 Farm Bill. NRCS provides, among other things, technical and 

financial assistance to private landowners to implement conservation 

practices on their land. NRCS’s Soil Science Division, along with other 

federal agencies, states, and other entities, makes and maintains an 

inventory of the soil resources of the United States and disseminates the 

results for both nonfarm and farm uses. RD provides loans, grants, and 

technical assistance to rural residents, businesses, and other entities.

 

8

GAO, Streamlining Government: Questions to Consider When Evaluating Proposals to 

Consolidate Physical Infrastructure and Management Functions, GAO-12-542

(Washington, D.C.: May 23, 2012) and GAO, Human Capital: Agencies Are Using Buyouts 

and Early Outs With Increasing Frequency to Help Reshape Their Workforces, 

GAO-06-324 (Washington, D.C.: Mar. 31, 2006).

Background
 

Page 5 GAO-14-288 Department of Agriculture

The workforces of USDA’s service center agencies are located in national 

headquarters operations, which include specialized offices in various 

locations,9 as well as in extensive field office structures, which include 

USDA service center locations.10 As of the end of fiscal year 2012, FSA’s 

workforce was located in more than 2,100 offices, with a total of about 

13,600 employees—about 1,300 in FSA’s headquarters operations and 

about 12,300 in field locations.11 NRCS’s workforce was located in 

approximately 2,900 offices, with a total of about 11,800 employees—

about 1,200 in NRCS’s headquarters operations and about 10,600 in field 

locations.12 RD’s workforce was located in more than 400 offices, with a 

total of about 5,100 employees—about 1,400 in its headquarters 

operations and about 3,700 in field locations.13

USDA’s Blueprint for Stronger Service is a departmental initiative 

announced by the Secretary of Agriculture in January 2012 that is 

intended to streamline operations and cut costs across the department. 

This initiative encompasses a number of efforts at the departmental and 

agency levels. Office closures announced under the initiative in fiscal year 

2012 resulted in the closure of more than 200 offices, facilities, and labs 

in eight USDA agencies, including at USDA’s service center agencies. As 

part of this initiative:

 

9

For the purpose of this report, we refer to employees in the service center agencies 

located in the Washington, D.C. locality pay area to be part of the agencies’ headquarters 

operations. In addition, based on information provided by the service center agencies, we 

considered employees in the following offices to be part of the headquarters operations. 

For FSA, these locations include Kansas City, Missouri; St. Louis, Missouri; and Salt Lake 

City, Utah. For NRCS, these include Fort Collins, Colorado; Fort Worth, Texas; 

Greensboro, North Carolina; Lincoln, Nebraska; Little Rock, Arkansas; and Portland, 

Oregon. For RD, this includes St. Louis, Missouri. Employees in all other duty stations are 

considered to be in field locations.

10USDA service centers are designed to be a single location where customers can access 

the services provided by FSA, NRCS, and RD. 

11FSA’s workforce is made up of two types of employees: (1) federal, primarily General 

Schedule employees subject to the Civil Service Reform Act, and (2) county office 

employees, who are hired by county committees elected by area farmers and only have 

select employment rights under the Civil Service Reform Act. Their salaries come from 

federal funds.

12The majority of NRCS’s permanent positions are classified under the General Schedule.

13The majority of RD’s permanent positions are classified under the General Schedule.
 

Page 6 GAO-14-288 Department of Agriculture

• FSA closed 125 offices (out of about 2,100 total offices) in 32 states. 

Based on information from FSA, these closures resulted in estimated 

net savings, starting in fiscal year 2013, of about $2.1 million.14 In 

choosing which offices to close, FSA officials told us they were guided 

by provisions in the 2008 Farm Bill, which requires that, to the 

maximum extent practicable, the agency must close offices with two 

or fewer permanent full-time employees and that were less than 20 

miles from another office before closing any office located more than 

20 miles from another office. FSA officials also reported that they 

closed unstaffed offices regardless of their distance from another 

office.15 In addition to closing offices, FSA offered four rounds of 

buyout or early retirement incentives to its employees in fiscal year 

2012. With limited exceptions, three of the four rounds were offered to 

staff in both headquarters operations and field locations, in some 

cases subject to a priority order. The fourth offer was limited to 

employees in offices selected for closures in fiscal year 2012. In 

response to these incentives, OPM and USDA data indicate that 682 

FSA employees accepted buyout or early retirement incentives, 

which, according to FSA officials, resulted in about $20 million in cost 

savings in fiscal year 2012.

• NRCS closed 24 soil survey offices (out of about 160 soil survey 

offices and about 2,800 offices overall) in 21 states.16 According to 

NRCS officials, these closures resulted in estimated savings of about 

$1.3 million in fiscal year 2013. NRCS officials told us that to 

determine which local soil survey offices to close, they reviewed 

offices’ funding, workload, and proximity to specific universities. For 

regional office closure determinations, officials told us they considered 

workload, proximity to transportation corridors, and equitable 

distribution of local offices in each region. In addition to closing 

offices, NRCS offered buyout and early retirement incentives to 

 

14Most of those office closures occurred in fiscal year 2012, but some occurred in fiscal 

year 2013.

15According to FSA officials, offices without any employees could be the result of 

vacancies not being backfilled due to staffing constraints. FSA employees from other 

locations had to travel to these offices weekly to provide service.

16According to NRCS officials, soil survey offices are specialized offices that do not 

directly serve agricultural producers. Their closure was part of a long-standing plan to 

reorganize the agency’s soil survey project offices. However, they can be located within 

service centers, which do serve the public. These closures did not necessarily affect the 

operation of the service centers.
 

Page 7 GAO-14-288 Department of Agriculture

employees affected by the soil survey office closures. According to

NRCS officials, 18 NRCS employees accepted buyout incentives, and 

a subset of those individuals also accepted early retirement incentives 

associated with its soil survey office closures in fiscal year 2012. The 

savings NRCS attributed to employees accepting those incentives 

was approximately $470,000 in fiscal year 2012.

• RD closed 43 offices (out of more than 400 total offices) in 17 states. 

According to RD officials, these closures resulted in estimated net 

savings, starting in fiscal year 2013, of about $710,000. In choosing 

which offices to close, RD officials told us that they used focus groups 

and weighed multiple criteria, including whether (1) an office location 

was in an isolated community, (2) a particular location served tribal 

lands, and (3) other USDA agencies were contemplating a closure in 

the same location. In addition, prior to the office closures, RD offered 

buyout and early retirement incentives to all optional and early 

retirement eligible employees, except for employees in two 

occupations.17 OPM data indicate that 599 RD employees accepted 

buyout or early retirement incentives in fiscal year 2012, which RD 

officials told us resulted in about $25 million in cost savings in fiscal 

year 2012.

Prior to this initiative, USDA’s service center agencies have closed 

offices. For example, FSA officials told us that the agency has closed 

hundreds of offices in the last 10 years as a result of staff reductions and 

workload changes.

OPM provides guidance to federal agencies on human capital 

management topics. For example, OPM issued the Human Capital 

Assessment and Accountability Framework, which includes five systems 

that provide a framework for human capital management for the federal 

government. This guidance states, among other things, that an effectively 

implemented workforce planning system results in the right balance of 

supervisory and nonsupervisory positions to best support the agency 

mission based on an analysis of customer needs and workload 

distribution. OPM also provides guidance to agencies on classification of 

grades and positions. For example, under the General Schedule, 

 

17RD exempted the following two occupation series from the incentives: (1) Engineer 

(0800) at all pay grade levels and locations, and (2) Information Technology Management 

(2210) at pay grade 12 in all locations and at pay grade 14 in St. Louis, Missouri.
 

Page 8 GAO-14-288 Department of Agriculture

agencies use a uniform set of OPM-issued standards to classify positions 

into occupation series within five occupational groups, including (1) 

professional and scientific positions, (2) administrative and management 

positions, (3) technical and medical support positions, (4) clerical and 

administrative support positions, and (5) other.18

At USDA, the Office of Human Resources Management directs 

implementation of the Human Capital Assessment and Accountability 

Framework and evaluates human capital management policies, among 

others, to determine how effectively they support human capital efforts to 

achieve program results. Among other things, and as follows, the office:

• Assists in the implementation of USDA’s Cultural Transformation, a 

set of initiatives launched in 2010 to promote, among others, diversity, 

inclusion, and high-performance.19 For example, the office issues a 

monthly report that tracks progress on various measures, including 

the diversity of the USDA workforce, performance management, and 

communication with employees.

• Provides guidance and oversight to USDA agencies on human capital 

planning and management. For example, the office has developed a 

draft human capital planning guide to aid its agencies in developing 

human capital plans. As part of its oversight of human capital 

management, the office oversees the implementation of a 2010 USDA 

policy on the ratio of supervisors to employees that, among other 

things, outlines a process for agencies to annually calculate their 

supervisory ratios and provide the results to USDA.20

USDA has a policy on organizational changes. Among other things, it 

states that USDA’s Secretary or Assistant Secretary for Administration 

must approve organizational changes that include, among other things, 

 

18Additional information on classification and qualifications for the General Schedule 

occupations is available on the OPM website, at http://www.opm.gov/policy-dataoversight/classification-qualifications/general-schedule-qualification-standards/. 

19USDA, The Cultural Transformation of USDA, Creating an Inclusive, High Performance 

Organization (Washington, D.C.: August 2010). 

20USDA, Departmental Regulation: Position Management and Vacancy Control, DR 4020-

250-002 (Washington, D.C.: Oct. 18, 2010).
 

Page 9 GAO-14-288 Department of Agriculture

the closure of an office.21 The policy also states that proposals for 

organizational changes such as office closures include a variety of 

detailed information, including (1) the circumstances giving rise to the 

proposal; (2) human resource management, financial, and facilities 

impacts; (3) a copy of an internal analysis on civil rights impact; and (4) 

verification from agency management that internal control requirements 

have been met.

In our past work, we have established leading practices for consolidation 

initiatives such as office closures.22 Specifically, such practices include 

the following:

• Identify and agree upon goals. The key to any consolidation initiative 

is the identification of and agreement on specific goals. Defining goals 

can also help agency leaders clarify the benefits associated with a 

consolidation and describe a future that will be both different from and 

better than the past.

• Present a business-case or cost-benefit analysis. Such an analysis 

can help agencies show stakeholders why a particular initiative is 

being considered and the range of alternatives considered to ensure 

they are using public funds most effectively.

• Identify stakeholders and develop a two-way communications 

strategy. Since stakeholders often view consolidation as working 

against their own interests, it is critical that agencies identify the 

relevant stakeholders and develop a two-way communications 

strategy that both addresses stakeholder concerns and conveys the 

rationale for and overarching benefits associated with the 

consolidation.

• Implement consolidations using change management practices. 

Implementing a consolidation requires the concentrated efforts of both 

leadership and employees. Agencies should have an implementation 

plan for the consolidation that includes, among other things, essential 

change management practices such as active, engaged leadership at 

the highest possible levels; a dedicated implementation team that can 

 

21USDA, Departmental Regulation: Organization, DR 1010-001 (Washington, D.C.: July 

20, 2006).

22GAO-12-542. 
 

Page 10 GAO-14-288 Department of Agriculture

be held accountable for change; and a strategy for documenting best 

practices and measuring progress toward the established goals of the 

consolidation.

In our past work, we have also established leading practices for 

implementing staff reductions through the use of buyout and early 

retirement incentives.23 Such practices include the following:

• Identify the reshaping goals of the agency. This will assist agencies in 

linking buyout and early retirement incentives to specific 

organizational objectives.

• Develop workforce reshaping strategies that fully consider alternative 

methods. This will help agencies identify whether alternatives to 

buyout and early retirement incentives may more effectively meet 

agency reshaping goals and could work in conjunction with these 

tools.

• Design buyout and early retirement incentives that demonstrate a 

clear relationship to the agency’s workforce reshaping goals and 

overarching strategic goals. This will help ensure that employees 

critical to the mission of an agency are retained.

• Design buyout and early retirement incentives that consider 

employees’ needs. Programs that do not do so may cause damage to 

the agency’s reputation or negatively affect employee morale and 

productivity.

• Develop a communications strategy early in the process. Regular 

communication with employees increases transparency in the process 

used to determine which positions may be eliminated. This in turn 

increases employee trust and maintains employee morale.

• Establish an evaluation system to identify and report relevant data on 

recipients of buyout and early retirement incentives. Agencies can use 

these data to assess how well the buyout and early retirement 

incentives are meeting or have met reshaping goals and whether they 

need to adjust their strategies.

 

23GAO-06-324. 
 

Page 11 GAO-14-288 Department of Agriculture

Of the six practices above, five are generally reinforced in the provisions 

of the Chief Human Capital Officers Act and OPM regulations 

implementing it. The one practice above that is not reflected in statutory 

and OPM requirements relates to establishing an evaluation system to 

identify and report relevant data on recipients of buyout and early 

retirement incentives.24

From fiscal years 2003 to 2012, the size of the workforces decreased at 

all three USDA service center agencies and the average number of 

employees per supervisor decreased at two of them. The decrease in the 

size of the workforces of USDA’s service center agencies accelerated in 

fiscal year 2012 (see figs. 1 and 2). Specifically, in each of the last 10 

years, the average decrease was approximately 4.5 percent in FSA, 1.4 

percent in NRCS, and 3.3 percent in RD. From fiscal years 2011 to 2012, 

the decrease was 9.2 percent in FSA, 3.8 percent in NRCS, and 14 

percent in RD. Other characteristics of their workforces, such as grade 

levels and occupation types, largely remained the same during this 

period.

 

24OPM officials told us that although there is no statutory or regulatory requirement for 

agencies to establish an evaluation system specifically for the use of buyout and early 

retirement incentives, there is a regulatory reporting requirement for agencies to report to 

OPM on their usage of buyout and early retirement incentives. See 5 C.F.R. § 576.104(b) 

(buyout incentives), 5 C.F.R. § 831.114(p) (early retirement incentives), and 5 C.F.R. § 

842.213(p) (early retirement incentives).

Size of the 

Workforces of USDA 

Service Center 

Agencies Decreased, 

but Other Workforce 

Characteristics 

Largely Remained 

Constant
 

Page 12 GAO-14-288 Department of Agriculture

Figure 1: Size of the Workforces of USDA’s Service Center Agencies from Fiscal 

Years 2003 to 2012
 

Page 13 GAO-14-288 Department of Agriculture

Figure 2: Declines in the Size of USDA’s Service Center Agencies’ Workforces

At USDA’s service center agencies, workforce decreases were smaller in 

headquarters operations than in field locations and smaller for career 

permanent employees than for employees with other appointments, such 

as temporary employees (see table 1). Specifically, from fiscal years 2003 

to 2012, the size of the workforce of each of the agencies’ headquarters 

operations decreased at a slightly slower average annual rate than the 

workforce of the agencies’ field locations. According to agency officials, 

workforce decreases over this 10-year period were attributed to various 

factors. At FSA, these decreases were due to budget constraints; at 

NRCS, officials said they were due to changes associated with the Farm 

Security and Rural Investment Act of 2002 (2002 Farm Bill)25 and the 

2008 Farm Bill; and at RD, officials said they were due to the need to stay 

within appropriated funding levels while other expenses increased, such 

as those associated with information technology, office space rental 

costs, and staff pay. We also reviewed the percentage change in the size 

of the service center agencies’ workforces from fiscal years 2011 to 2012 

and found that the workforce decreases were smaller in headquarters 

operations than in the field for FSA and RD, but they were larger in 

headquarters operations than in the field for NRCS. Based on our 

analysis, some of these changes may be due to staff reduction efforts 

undertaken by the agencies, while others may be attributed to natural 

attrition. As it relates to the average annual decline in the number of 

employees by appointment type, the number of career permanent 

 

25Pub. L. No. 107-171 (2002).
 

Page 14 GAO-14-288 Department of Agriculture

employees, which make up the majority of the agencies’ workforces, was 

less than the average annual decline in the number of other employees, 

such as temporary employees.26 This was also the case for the 

percentage change in the size of the workforces from fiscal years 2011 to 

2012. Most of the agencies’ temporary employees were in field locations 

in fiscal year 2012.27 FSA officials told us that their temporary workers 

perform many of the same functions as their career permanent 

employees. For example, program technicians who implement 

procedures, regulations, and operations of a county office’s administrative 

program area, can be temporary or career permanent employees.

Table 1: Changes in the Size of the Workforces of USDA’s Service Center Agencies by Location and Type of Appointment 

Farm Service Agency 

Natural Resources 

Conservation Service Rural Development 

Average annual percentage change in the size of the workforces from fiscal years 2003 to 2012

Headquarters operations -4.5% 0.2% -2.5% 

Field locations -4.6% -1.6% -3.6% 

Career permanent appointmentsa -2.5% -1.0% -3.2% 

Other appointments -29.4% a -1.6% -5.8% 

Percentage change in the size of the workforces from fiscal years 2011 to 2012

Headquarters operations -6.6% -6.4% -9.7% 

Field locations -9.4% -3.5% -15.6% 

Career permanent appointmentsa -7.9% -2.3% -12.7%

Other appointments -10.4% a -17.8% -38.6%

Sources: GAO analysis of the Office of Personnel Management and USDA data.

a

This analysis was done for employees on full- and part-time year-round schedules.

From fiscal years 2003 to 2012, the average number of employees per 

supervisor, characterized in a supervisor-to-employee ratio, decreased at 

FSA and RD but remained relatively constant at NRCS (see fig. 3).28

 

26This analysis was done for full- and part-time year-round employees.

27Specifically, about 99 percent of temporary employees at FSA were in the field. At 

NRCS, 91 percent were in the field, and at RD, 71 percent were in the field.

28In this report, we use the term “supervisors” to refer to supervisor or manager (code 2) 

as defined by OPM, The Guide to Data Standards, Part A: Human Resources, Update 12 

(Washington, D.C.: May 1, 2013). We used this definition and calculated supervisory 

ratios in accordance with USDA’s guidance to its agencies.
 

Page 15 GAO-14-288 Department of Agriculture

NRCS officials told us that their supervisory ratio has not declined in the 

past 10 years because of restructuring and additional responsibilities 

assumed by its workforce as a result of the 2002 Farm Bill. During this 

10-year period, there were more employees per supervisor in FSA’s 

headquarters operations compared with its field locations. At NRCS and 

RD, there were generally fewer employees per supervisor at their

headquarters operations than at their field locations. For example, in 

fiscal year 2012, the supervisor-to-employee ratio in FSA’s headquarters 

operations was approximately 1:5 compared with 1:4 in its field locations. 

At NRCS, the supervisor-to-employee ratio in its headquarters operations 

was approximately 1:6 compared with 1:14 in its field locations. At RD, 

the supervisor-to-employee ratio in its headquarters operations was 

approximately 1:6 compared with 1:8 in its field locations.
 

Page 16 GAO-14-288 Department of Agriculture

Figure 3: Supervisor-to-Employee Ratios of the Workforces of USDA’s Service 

Center Agencies in Fiscal Years 2003 and 2012

a

For the purpose of this report, we calculated a single, agency-wide supervisory ratio for FSA. 

Determining a separate supervisory ratio for the General Schedule workforce and county office 

workforce at FSA would not have significantly changed our results. For example, in 2003, the 

supervisory ratio for FSA’s county office workforce was 1:5.9, and for the remaining workforce it was 
 

Page 17 GAO-14-288 Department of Agriculture

1:5.8, or approximately 1:6 for each. In 2012, the supervisory ratio for FSA’s county office workforce 

was 1:4.0, and for the remaining workforce it was 1:3.6, or approximately 1:4 for each.

The median pay grades of the workforces of USDA’s service center 

agencies remained relatively constant.29 Specifically, from fiscal years 

2003 to 2012, the median pay grade for FSA stayed at pay grade 7, and 

for NRCS and RD it stayed at pay grade 11. The median pay grades for 

the service center agencies’ headquarters operations from fiscal years 

2003 to 2012 were higher than in the field locations at FSA and NRCS but 

the same, at 11, at RD. For example, at NRCS, the median pay grade 

from fiscal years 2003 to 2012 was 12 or 13 in the agency’s headquarters 

operations and 11 in its field locations. With respect to the grade 

distribution of supervisors, these remained relatively constant at FSA and 

RD, but the pay grades of the majority of supervisors increased at NRCS. 

From fiscal years 2003 to 2012, the majority of supervisors at FSA were 

in pay grades 10 to 12, and at RD, the majority of supervisors were in pay 

grades 13 to 15. At NRCS, the majority of supervisors were in pay grades 

10 to 12 in fiscal year 2003, but by fiscal year 2012, the majority were in 

pay grades 13 to 15. NRCS officials told us that the pay grades of the 

majority of supervisors have increased in the last 10 years due to the 

increasing complexity of the agency’s work, primarily driven by changes 

enacted in the 2002 Farm Bill.

The occupational makeup of USDA’s service center agencies also 

remained relatively stable over the 10-year period (see fig. 4). 

Specifically, the majority of the FSA and RD workforces were employed in 

administrative and management occupations, such as loan specialists 

who provide loan servicing and counseling assistance to borrowers. The 

majority of the NRCS workforce was employed in professional and 

scientific occupations, such as civil engineers, some of whom were 

responsible for providing technical guidance and leadership in the overall 

planning, design, installation, and maintenance of the engineering phases 

of soil and water conservation projects. Additional information on the 

workforces of USDA’s service center agencies in fiscal year 2012, such 

as ethnicity and race, mission-critical occupations, length of service, and 

retirement eligibility, is available in appendix II.

 

29For the purpose of this report, we combined the pay plans of the General Schedule and 

county office employees when determining median pay grades of the FSA workforce. The 

NRCS and RD reported pay grades are for employees in the General Schedule.
 

Page 18 GAO-14-288 Department of Agriculture

Figure 4: Changes in the Occupational Composition of USDA’s Service Center Agencies from Fiscal Years 2003 to 2012

a

For FSA, the “other” occupations make up less than 0.5% of the workforce from fiscal years 2003 to 

2012.

b

Other occupations include those that cannot be included in other occupational groups either because 

the duties are unique or because they are complex and do not fit clearly into a single occupational 

group. These occupations include, for example, safety and occupational health management, 

community planning, and security administration.
 

Page 19 GAO-14-288 Department of Agriculture

In fiscal year 2012, USDA policy on supervisory ratios, which targeted a 

uniform supervisory ratio of one supervisor for at least nine employees at 

all USDA agencies, did not align with OPM guidance. OPM’s guidance 

states that analyzing customer needs and workload distribution can help 

agencies achieve the right balance of supervisory and nonsupervisory 

positions to support their missions. USDA policy, issued in October 2010, 

did not reflect such an approach, but rather it stated that all agencies 

should aim for a target ratio of one supervisor for at least nine employees 

(1:9). USDA officials were not able to provide us with a documented basis 

for this target ratio. In fiscal year 2012, our analysis showed that NRCS’s 

supervisory ratio, at 1:12, met the USDA target of one supervisor for at 

least nine employees, but FSA and RD—at 1:4 and 1:7, respectively—did 

not.30 FSA and RD officials told us that they made improving their 

supervisory ratios a management goal, but that meeting USDA’s target 

may be difficult. Specifically, FSA officials told us that it may not be 

feasible for FSA to meet the department’s target ratio because, due to 

staff reductions, more county executive directors were involved in direct 

program delivery in addition to supervising others performing that work. 

RD officials told us that managing the supervisory ratios in accordance 

with the USDA target was difficult as RD downsized its workforce in 

recent years. However, the service center agencies were striving to meet 

a target that may not have supported their missions because USDA’s 

policy did not ask agencies to determine a supervisory ratio target based 

on a documented analysis of their customer needs and workload 

distribution.

In addition, USDA did not ensure that the service center agencies 

followed its guidance when calculating their specific supervisory ratios. 

Regardless of what ratio agencies are aiming to achieve, federal internal 

control standards state that managers should exercise control to achieve 

reasonable assurance that the objectives of the agency are being 

achieved.31 USDA’s guidance to its agencies on implementing its policy 

on supervisory ratios specified the formula agencies should use when 

calculating supervisory ratios, such as the type of employees to consider 

 

30We use the term “supervisors” to refer to supervisor or manager (code 2) as defined by 

OPM, The Guide to Data Standards, Part A: Human Resources, Update 12 (Washington, 

D.C.: May 1, 2013). We used this definition and calculated supervisory ratios in 

accordance with USDA’s guidance to its agencies.

31GAO, Internal Control: Standards for Internal Control in the Federal Government, 

GAO/AIMD-00-21.3.1 (Washington, D.C.: Nov. 1, 1999).

USDA’s Policy on 

Supervisory Ratios 

Did Not Align with 

OPM Guidance in 

Fiscal Year 2012
 

Page 20 GAO-14-288 Department of Agriculture

as supervisors.32 However, none of USDA’s service center agencies 

followed the departmental guidance. Specifically, the service center 

agencies considered more types of employees as supervisors than those 

identified in the USDA guidance. USDA officials could not provide 

documentation that the guidance was communicated to the service center 

agencies but told us the guidance would have been circulated at the time 

of the policy’s issuance, in 2010, to the mission areas’ human resources 

directors. Further, USDA officials told us that supervisory ratios are one of 

several measures that could be used to inform reorganization efforts. 

However, because the service center agencies did not follow the USDA 

guidance, their calculated supervisory ratios—a workforce analytic that 

department management could use to help make human capital 

decisions—were not comparable to one another. Without comparable 

information on supervisory ratios, USDA cannot have a reasonable 

assurance that the data it uses to support its human capital objectives, 

such as those regarding reorganizations, are sound.

In fiscal year 2012, USDA’s service center agencies followed or partially 

followed four leading practices when closing offices.33 In addition, FSA 

was subject to specific office closure provisions in the 2008 Farm Bill, and 

officials provided information related to those provisions for its fiscal year 

2012 office closure decisions. FSA and NRCS followed or partially 

followed six leading practices when using buyout and early retirement 

incentives, and RD followed or partially followed five of those six.34

 

32This guidance stated that only employees coded with supervisory code 2, which is one 

of five potential supervisory codes, should be considered to be supervisors for the 

purpose of calculating supervisory ratios.

33GAO-12-542. 

34GAO-06-324. 

USDA’s Service 

Center Agencies 

Generally or Partially 

Followed Leading 

Practices When 

Closing Offices and 

Reducing Staff in 

Fiscal Year 2012
 

Page 21 GAO-14-288 Department of Agriculture

USDA’s service center agencies partially or fully followed all four leading 

practices we reviewed for successful office closures.35 Specifically, NRCS 

fully followed three of the four leading practices and partially followed one. 

FSA and RD fully followed two of the four leading practices and partially 

followed two others. Figure 5 lists these leading practices and the extent 

to which each service center agency followed them when implementing 

fiscal year 2012 office closures.

Figure 5: Extent to Which USDA’s Service Center Agencies Followed Leading 

Practices for Successful Office Closures 

All three service center agencies identified and agreed upon goals for 

their office closures

(FSA , NRCS , RD , as shown in fig. 5). As we previously 

reported, defining goals can help decision makers understand what 

problems need to be fixed, how to balance differing objectives, and how 

to achieve long-term goals. The broad goals of each agency’s fiscal year 

2012 office closures were defined by USDA’s Blueprint for Stronger 

Service initiative, which officials said is intended to streamline operations, 

cut costs, and make more effective use of USDA’s employees to improve 

service to USDA customers and increase efficiency. In addition, each of 

the service center agencies defined other goals for their fiscal year 2012 

office closures. Specifically, FSA officials told us that the agency aimed to 

improve service by having fewer but better-staffed offices. NRCS 

 

35GAO-12-542. 

USDA’s Service Center 

Agencies Followed or 

Partially Followed Leading 

Practices for Office 

Closures

Identify and Agree Upon Goals
 

Page 22 GAO-14-288 Department of Agriculture

documented specific goals associated with its closures, such as 

improving its technical services and recruiting a more diverse workforce 

while retaining current employees by ensuring offices were in more 

desirable locations. At RD, officials told us that their goals included 

streamlining operations in small offices and better leveraging resources.

NRCS followed and FSA and RD partially followed the leading practice of 

presenting a business-case or cost-benefit analysis (FSA , NRCS , 

RD , as shown in fig. 5). According to the National Research Council, a 

business-case analysis can make clear underlying assumptions, 

alternatives considered, the full range of costs and benefits, and the 

potential consequences for an organization and its missions.36 OMB 

guidelines for agencies to consider when conducting a cost-benefit 

analysis of federal programs say that such analysis should include a 

policy rationale, explicit assumptions, an evaluation of the alternatives, 

and a plan to verify program results.37 Further, federal internal control 

standards call for federal agencies to document key decisions and to 

manage and maintain the documentation and make it available for 

examination.38 USDA has a policy on making organizational changes that 

requests agencies to submit information on proposed closures that 

include some elements of a business-case analysis, such as a detailed 

explanation of the circumstances giving rise to the proposed closure and 

verification from agency management that internal control policies have 

been met.39 However, according to a USDA official, the Secretary of 

Agriculture waived the department’s requests for such proposals for the 

fiscal year 2012 office closures associated with the department’s 

Blueprint for Stronger Service, saying that agencies had already done 

work to assist in making decisions on the closures. In addition, the policy 

does not ask agencies to document other elements of a business-case 

analysis, such as underlying assumptions and alternatives considered.

 

36National Research Council, Investments in Federal Facilities: Asset Management 

Strategies for the 21st Century (Washington, D.C.: National Academies Press, 2004).

37 OMB, Guidelines and Discount Rates for Benefit-Cost Analysis of Federal Programs,

OMB Circular A-94 (Washington, D.C.: Oct. 29, 1992).

38GAO/AIMD-00-21.3.1.

39USDA, Departmental Regulation: Organization, DR 1010-001 (Washington, D.C.: July 

20, 2006).

Present a Business-Case or 

Cost-Benefit Analysis
 

Page 23 GAO-14-288 Department of Agriculture

NRCS prepared a written business-case analysis that explained its 

decision making. This analysis included information that outlined the 

current state of the agency’s Soil Science Division; reasons for proposed 

organizational changes; and options considered, including pros and cons 

for each. According to NRCS officials, the agency had prepared 

documentation describing the case for office closures before USDA 

waived its request for such documentation. NRCS officials used its 

business-case documentation to aid in communication by sending the 

document to external stakeholders to explain the rationale behind their 

decisions.

Unlike NRCS, FSA and RD officials told us that they considered a variety 

of office closure options to achieve their stated goals, but FSA officials 

told us that no business-case or cost-benefit analyses were prepared, 

and RD officials stated that due to leadership turnover they could not 

locate any analyses that may have been prepared. For example, FSA 

officials told us the agency considered alternatives, such as closing more 

offices than were eventually closed. RD officials told us they considered 

several factors in their decision regarding selecting offices for closures, 

such as the type of communities where offices were located and whether 

other USDA agencies were planning to close offices at that location, and 

consulted with focus groups. However, neither FSA nor RD documented 

these considerations in a business-case or cost-benefit analysis. A USDA 

official said the agencies did not prepare written analyses because USDA 

waived the policy for the office closures associated with the department’s 

Blueprint for Stronger Service. The policy that was waived was USDA’s 

policy on making organizational changes. However, this policy does not 

include all elements of a business-case or cost-benefit analysis, such as 

considering alternatives and documenting underlying assumptions. 

Without presenting business-case or cost-benefit analyses, FSA and RD 

cannot demonstrate to their workforces, agricultural producers, and other 

stakeholders the alternatives they considered in their decision making 

and the steps they took to make effective use of public funds in support of 

their missions. For example, representatives of employee unions at RD 

told us that it was unclear how RD management chose offices to close. At 

FSA, employee group representatives raised questions about why the 

agency was choosing to close field offices rather than consolidate offices 

above the field office level. In addition, employee group representatives 

and those commenting on the proposed closures during public meetings 

raised questions about whether the decisions made sense from a 
 

Page 24 GAO-14-288 Department of Agriculture

budgetary perspective or whether criteria used to close FSA’s unstaffed 

offices took into account factors such as workload or the number of 

beginning, older, and disadvantaged producers served by these offices.40

FSA officials acknowledged that producing a formal business-case or 

cost-benefit analysis would have provided a stronger basis for the 

agency’s decision making.

The three service center agencies fully followed the leading practice of 

identifying relevant stakeholders and developing a two-way 

communications strategy (FSA , NRCS , RD , as shown in fig. 5). 

We have reported that stakeholders often view actions such as office 

closures as working against their own interests, and that it is critical for 

agencies to identify the relevant stakeholders and develop an ongoing 

two-way communications strategy that addresses stakeholder concerns 

but also conveys a rationale for and benefits of the closures. Specific 

stakeholder groups varied for each agency, but all agencies identified 

local officials and affected employees as stakeholders. To communicate 

with stakeholders, each agency used specific procedures as follows:

• FSA officials told us that the primary takeaway from the agency’s 

office closures in 2006 was the importance of clear, consistent, and 

thorough communication throughout the closure process. For its 2012 

closures, FSA advertised and held public meetings in each county 

where an office was proposed for closure. At its public meetings, FSA 

provided information on the reasons for the proposed office closures, 

noted the concerns of stakeholders about the closures, and allowed 

for questions and answers. To communicate with internal 

stakeholders, according to information provided by FSA officials, state 

executive directors sent memos to affected employees and invited 

them to contact their state executive director with any questions or 

concerns.

• NRCS officials told us that prior to the office closure announcement, 

they discussed the possibility of office closures with selected internal 

and external stakeholders to gather their input. Following the 

announcement, officials told us that they communicated with internal 

stakeholders largely through regular teleconferences such as weekly 

 

40A beginning farmer or rancher is one who (1) has not operated a farm or ranch, or who 

has operated a farm or ranch for not more than 10 consecutive years, and (2) will 

materially and substantially participate in the operation of the farm or ranch.

Identify Relevant Stakeholders 

and Develop a Two-Way 

Communications Strategy
 

Page 25 GAO-14-288 Department of Agriculture

telephone meetings to keep them updated on the status of the 

closures. NRCS officials said a few stakeholders expressed concern 

with the closures or provided alternatives, but the agency was not 

able to fully respond to their input due to lack of time. Officials 

acknowledged that giving stakeholders an opportunity to participate in 

the process can be helpful in enhancing their partnerships.

• RD officials said that state leaders used various means to 

communicate with both internal and external stakeholders. For 

example, prior to making closure decisions, RD officials told us they 

used focus groups to gather input from stakeholders and, following 

the announcements, state leaders shared information about the 

closures through town hall meetings, local media, and written 

communications. RD officials also told us that their state leaders were 

in close contact with union representatives and that they did not need 

to formally bargain with the unions or address grievances.

USDA’s service center agencies partially followed the leading practice of 

using change management practices (FSA , NRCS , RD , as 

shown in fig. 5). The leading practices state that to minimize the duration 

and the significance of any reduced productivity and effectiveness, 

agencies should use change management practices such as having (1) 

active, engaged leadership at the highest possible levels; (2) a dedicated 

implementation team; and (3) a strategy for measuring progress toward 

goals and using lessons learned. The service center agencies followed 

most of these practices, but they did not measure progress toward all 

goals.

Departmental and agency leaders were actively involved in the service 

center agencies’ fiscal year 2012 office closures. At the departmental 

level, the Secretary announced all proposed closures in January 2012. In 

addition, leaders such as FSA’s administrator and deputies, and RD 

officials told us that their state directors and other senior leaders were 

directly involved. As our leading practices for office closures state, having 

such leadership involvement can help set the direction, pace, and tone of 

the closures, and provide a clear, consistent rationale for agency staff.

Each service center agency also used an implementation team to 

manage the work of the closures. FSA officials told us they had an 

implementation team consisting of representatives from most of FSA’s 

divisions and several departmental offices, including officials from FSA’s 

field operations, Information Technology Services Division, and USDA’s 

Office of Civil Rights. At NRCS, officials told us that they assembled 

Use Change Management 

Practices
 

Page 26 GAO-14-288 Department of Agriculture

teams of senior leaders to develop proposals for and implement the 

closures. At RD, officials told us that their property management directors, 

among others, were part of their implementation team, and that those 

directors met monthly with their counterparts at FSA and NRCS to plan 

for the closings and the possible impact on the service center agencies.

Each agency documented that they tracked cost savings—a major goal of 

the office closures. However, the service center agencies did not have 

specific strategies in place to measure progress toward other stated office 

closure goals such as NRCS’s goal to improve technical services or 

FSA’s goal to improve service. For example, NRCS provided us with 

information showing that the number of activities it has undertaken 

associated with its technical soil services steadily increased from fiscal 

years 2011 to 2013. However, these activities were only partially related 

to work performed by soil survey offices, and NRCS did not provide us 

with information on how those metrics were affected by its soil survey 

office closures. At RD, officials told us that closing offices had helped 

them with their goals to leverage resources and streamline operations, 

but they could not demonstrate these benefits using specific metrics. 

Similarly, FSA officials said that overall, agricultural producers’ 

participation in FSA programs has not decreased following the office 

closures, but they did not provide specific participation information in 

areas where offices had closed. USDA’s policy on making organizational 

changes asks agencies to detail the circumstances giving rise to the 

proposed changes, but it does not ask agencies to measure progress 

toward office closure goals. However, our leading practices for office 

closures state that agencies closing offices should have metrics of 

success that should show progress toward achieving an intended level of 

performance or results. In addition, standards for internal control in the 

federal government call for agencies to ensure that performance 

measures and indicators have been established and that actual 

performance data are compared and analyzed against goals.41 Without 

metrics, officials may lack information to help them make any needed 

midcourse corrections, improve policy and operational effectiveness 

following the closures, or inform stakeholders on progress or outcomes.

Officials from all three agencies told us they used lessons learned from 

prior rounds of office closures to execute their fiscal year 2012 office 

 

41GAO/AIMD-00-21.3.1. 
 

Page 27 GAO-14-288 Department of Agriculture

closures. As we previously reported, using lessons learned is a leading 

practice that can aid in successful office consolidations such as office 

closures. FSA officials used a checklist that the agency created as part of 

its 2006 office closures to help implement the closures and ensure 

specific steps were taken. FSA officials told us that using this checklist 

helped smooth the closure process. NRCS officials stated that the agency 

used experiences from 2011 office closures in its Resource Conservation 

and Development Division to inform elements of its fiscal year 2012 

closures such as devising a placement strategy for affected employees. 

RD officials told us that they close offices on a regular basis and have 

extensive knowledge of how to do so. They also told us that they worked 

to capture lessons learned by, for example, helping to update USDA’s 

Real Property Leasing Handbook to better address leasing issues related 

to office closures based in part on lessons learned from the fiscal year 

2012 closures.

In fiscal year 2012, FSA’s office closure decisions were subject to section 

14212(b) of the 2008 Farm Bill, which specifies an order for FSA office 

closures and requires public meetings and congressional notifications of 

proposed office closures.42 Under section 14212(b), offices that have two 

or fewer permanent full-time employees and that are located less than 20 

miles from another FSA office are required, to the maximum extent 

practicable, to be closed before closing any office located more than 20 

miles from another FSA office. We found that FSA decided to close 125 

offices in fiscal year 2012.43 Of the 125 offices closed, 27 had no 

permanent full-time employees and were located more than 20 miles from 

another FSA office.44 The 98 other closed offices had two or fewer 

permanent full-time employees and were located less than 20 miles from 

another office but were not necessarily closed first. FSA officials told us 

that the agency determined the timing of office closures based on 

information collected from state directors on when the offices could notify 

 

42Food, Conservation, and Energy Act of 2008, Pub. L. No. 110-246, tit. XIV, § 14212(b) 

(2008).

43The decision to close these offices was made in fiscal year 2012, but the office closures 

occurred between June 1, 2012, and March 1, 2013.

44According to FSA officials, offices without any employees could be the result of 

vacancies not being backfilled due to staffing constraints. FSA employees from other 

locations had to travel to these offices weekly to provide service.

The 2008 Farm Bill and 

the Farm Service Agency’s 

Office Closures
 

Page 28 GAO-14-288 Department of Agriculture

employees, schedule physical moves, and take other necessary actions 

to close. FSA held a public meeting within 30 days of announcing the 

proposed closure in each county where the office proposed for closure 

was located. FSA also provided us with documentation of notifications 

sent to congressional committees and members of the proposed office 

closures showing that they were sent more than 90 days before FSA 

made its final decision regarding the office closures. Additional 

information on the FSA office closures and applicable provisions in the 

2008 Farm Bill can be found in appendix III.

USDA’s service center agencies partially followed or fully followed most of 

the six leading practices we have identified for using buyout and early 

retirement incentives.45 FSA fully followed two of the leading practices 

and partially followed four others. NRCS fully followed five leading 

practices and partially followed one. RD fully followed four leading 

practices, partially followed one, and did not follow one. Figure 6 lists 

these leading practices and the extent to which each service center 

agency followed them when implementing fiscal year 2012 buyout and 

early retirement incentives.

 

45GAO-06-324. 

USDA’s Service Center 

Agencies Followed or 

Partially Followed Most 

Leading Practices for 

Using Buyout and Early 

Retirement Incentives
 

Page 29 GAO-14-288 Department of Agriculture

Figure 6: Extent to Which USDA’s Service Center Agencies Followed Leading 

Practices for Using Buyout and Early Retirement Incentives

USDA’s service center agencies followed the leading practice of 

identifying reshaping goals when using buyout and early retirement 

incentives (FSA , NRCS , RD , as shown in fig. 6). As we 

previously reported, identifying reshaping goals can help agencies link 

buyout and early retirement incentives to specific organizational 

objectives. As was the case with office closures, all three agencies cited a 

need to address budget reductions as a primary goal in their decisions to 

offer buyout and early retirement incentives in fiscal year 2012. The 

agencies also stated additional goals. For example, in a request to USDA 

on the need to use the incentives in fiscal year 2012, FSA listed a number 

of organizational objectives, including reducing administrative complexity, 

optimizing service delivery, and increasing supervisory ratios. In its 

request to USDA, NRCS stated that using buyout and early retirement 

incentives could help the agency implement goals such as improving its 

science and technology support delivery systems by, among other things, 

reorganizing its Soil Survey Program. In its request to USDA, RD stated 

that using the incentives would assist them in eliminating unnecessary 

duplication of functions.

USDA’s service center agencies followed the leading practice of 

developing strategies that fully consider alternative methods when using 

Identify Reshaping Goals

Develop Strategies That Fully 

Consider Alternative Methods
 

Page 30 GAO-14-288 Department of Agriculture

buyout and early retirement incentives (FSA , NRCS , RD , as 

shown in fig. 6). As we previously reported, considering alternatives to 

using buyout and early retirement incentives can help agencies identify 

whether the alternatives may more effectively meet their reshaping goals 

and how the incentives could work in conjunction with other options. In 

their proposals to use the incentives, all three agencies reported 

considering other options to address budget shortfalls and used 

incentives in conjunction with other options to achieve their workforce 

reshaping goals. Specifically, they reported considering such tools as 

furloughs and Reductions in Force and provided various reasons for 

choosing not to implement them. For example, RD officials told us that 

using buyout and early retirement incentives instead of furloughs and 

Reductions in Force helped them avoid negative impacts such as 

disruption to the workforce, decreased employee morale, and decreases 

in diversity that can happen when implementing a Reduction in Force. In 

addition to buyout and early retirement incentives, all three agencies 

reported using additional workforce reshaping options such as hiring 

freezes, reassigning employees, or reducing temporary positions.

NRCS followed, FSA partially followed, and RD did not follow the leading 

practice of demonstrating a clear linkage to workforce reshaping or 

overall strategic goals when using buyout and early retirement incentives 

(FSA , NRCS , RD , as shown in fig. 6). We have reported that 

designing programs that demonstrate a clear relationship between an 

agency’s workforce reshaping goals helped agencies achieve those 

goals. NRCS presented clear linkages to its workforce reshaping goals by 

offering the buyout incentive only to employees directly associated with its 

soil survey reshaping plan. Specifically, NRCS’s proposal to use buyout 

and early retirement incentives discusses how using the incentives will 

create savings to help improve its science and technology delivery 

support systems by reorganizing its Soil Survey Program and reducing 

the number of Soil Survey Offices in operation. The request also 

discusses how workforce planning will help the agency address both a 

projected loss of positions and any impact on agency operations. Further, 

the agency’s fiscal year 2013-2017 workforce plan, which includes 

information on the fiscal year 2012 reorganization, projected that buyout 

and early retirement incentives might increase expected retirements, 

thereby creating a need to enhance mentoring and on-the-job training 

programs to assist in knowledge transfer.

FSA partially linked its buyout and early retirement incentives to its 

workforce reshaping and overarching strategic goals using a selection 

priority that targeted certain locations and positions to help ensure its 

Demonstrate a Clear Linkage 

to Workforce Reshaping or 

Overarching Strategic Goals
 

Page 31 GAO-14-288 Department of Agriculture

continued capacity to deliver core mission programs. However, while FSA 

completed a broad workforce analysis in 2011, it had not updated its 

human capital plan or workforce plan at the time it was making decisions 

to offer buyout and early retirement incentives, and agency officials told 

us that this analysis was not likely used to determine FSA’s selection 

priority. As a result, FSA could not demonstrate whether they had 

workforce goals that linked to their offerings, and they could not show 

whether the remaining workforce had the right balance of skills in the right

locations to support its mission. FSA’s buyout and early retirement 

incentives may have created unintended shortages of employees with 

certain skills or created imbalances that could hamper mission 

accomplishment. For example, FSA officials told us that they are 

assigning new responsibilities to employees to redistribute work 

performed by employees who took the buyout and early retirement 

incentives. FSA officials also noted that because the incentives were 

voluntary, the agency did not have control over which employees 

accepted them.

RD’s buyout and early retirement incentives were not linked to workforce 

reshaping or overarching strategic goals. Unlike the actions taken at FSA 

and NRCS, RD’s incentives were not targeted and were available to any 

staff member eligible for retirement or early retirement, except for 

employees in two occupations.46 According to our analysis of OPM data, 

there were about 2,400 RD employees eligible for retirement or early 

retirement, and RD exempted approximately 100 employees from the 

incentives, or about 4.2 percent of those eligible. In addition, RD officials 

did not have a human capital or workforce plan to clearly document links 

between its incentives and its workforce reshaping goals. RD officials told 

us that the agency needed to reduce its workforce by as many people as 

possible to address significant budget decreases. However, by offering 

incentives to much of its workforce, RD lost a significant portion of its 

ability to control the makeup of its workforce, which could impact its ability 

to accomplish its mission. Specifically, without linking buyout and early 

retirement incentives to workforce reshaping or broader strategic goals, 

RD could not show whether its remaining workforce has the right balance 

of skills in the right locations to support its mission. For example, our 

analysis of OPM data indicates that, of the approximately 600 employees 

 

46RD exempted the following occupation series from the incentives: Engineer (0800) at all 

pay grade levels and locations, and Information Technology Management (2210) at pay 

grade 12 in all locations and at pay grade 14 in St. Louis, Missouri.
 

Page 32 GAO-14-288 Department of Agriculture

who accepted buyout or early retirement incentives in fiscal year 2012, 

approximately 455 employees served in occupations defined by RD as 

mission critical.

NRCS and RD followed and FSA partially followed the leading practice of 

considering employees needs when using buyout and early retirement 

incentives (FSA , NRCS , RD , as shown in fig. 6). As we have 

reported, designing programs that consider employees’ needs can help 

employees cope with changes. Officials told us that employees from the 

three service center agencies were able to take department-wide 

retirement training. In addition, RD officials told us they hosted their own 

counseling sessions to help their employees decide whether to accept the 

incentives. FSA and NRCS also requested to use buyout and early 

retirement incentives in conjunction with office closures. Officials from 

NRCS told us that the agency attempted to relocate employees to 

locations that would not pose undue hardship. In addition, NRCS 

conducted a Civil Rights Impact Analysis to review office closures and 

noted that using buyout and early retirement incentives was intended to 

mitigate negative impacts on affected employees. FSA officials said that 

unions expressed some concerns about the agency’s notification 

procedures, their ability to bargain on some issues, and the short period 

of time that employees were given to decide whether to accept the 

incentives. FSA officials told us that they were not able to offer much time 

for employees to make decisions because the agency needed to separate 

employees as early as possible in the fiscal year. However, FSA officials 

said they built more time into the process when using the incentives in 

fiscal year 2013. Officials from all three agencies reported that no 

grievances were filed as a result of their buyout and early retirement 

incentives.

NRCS and RD fully followed and FSA partially followed the leading 

practice of developing a communications strategy early in the process 

when using buyout and early retirement incentives (FSA , NRCS , 

RD , as shown in fig. 6). Prior to receiving authority to use buyout and 

early retirement incentives, USDA management notified union 

representatives, including those represented by the service center 

agencies, that it had applied to OPM for the authority to offer buyout and 

early retirement incentives. Once the department received the authority to 

use the incentives, and the service center agencies finalized their 

incentive offers, each agency issued a notice to its employees that 

included key information such as answers to frequently asked questions 

and information on how employees could contact human resources staff 

for more details. NRCS officials told us that they held regular telephone 

Consider Employees’ Needs

Develop a Communications 

Strategy Early in the Process
 

Page 33 GAO-14-288 Department of Agriculture

and videoconference meetings with staff eligible for the incentives and 

provided updates via e-mail. RD officials said they met with employees 

who expressed interest in the incentives and conducted multiple sessions 

with eligible retirees to ensure that they were aware of their options. FSA 

provided uniform notices to employees ahead of each buyout and early 

retirement offering that described who was eligible and included 

responses to frequently asked questions, but it did not have specified 

strategies for communicating on a regular basis with its employees. 

Employee group representatives said they were confused or had 

concerns about the incentives. For example, FSA’s notice to employees 

regarding its incentives did not provide the reasons behind its selection 

priority for determining employees’ eligibility, and union representatives 

told us that some employees expressed concern that they were excluded 

from eligibility for nonmission related reasons or that their location was 

being targeted for downsizing. We have reported that developing a 

communications strategy early in the process can build an understanding 

of the purpose of planned changes, which can improve transparency, 

increase employee trust and help maintain employee morale. Subsequent 

to fiscal year 2012, FSA has improved its communications to employees 

in this area. For example, in its fiscal year 2013-2017 human capital plan, 

FSA discusses how it determines buyout eligibility, and that the agency 

would likely need to use early retirement incentives to mitigate future 

funding reductions. Officials from all three agencies noted that no 

grievances were filed in relation to their buyout and early retirement 

incentives.

USDA’s service center agencies partially followed the leading practice of 

establishing an evaluation system when using buyout and early 

retirement incentives (FSA , NRCS , RD , as shown in fig. 6). We 

have reported that establishing an evaluation system to review the use of 

such incentives after they have been offered and implemented can help 

agencies assess the longer-term effectiveness of using the incentives. 

For example, agencies could compare the length of service for 

employees with employee decisions about accepting buyout and early 

retirement incentives. Agencies could then use that information to 

determine the composition and timing of future offers. In addition, 

agencies could analyze whether the savings generated by buyout and 

early retirement incentives would likely provide the best use of resources 

in the future compared with other separation strategies, such as 

involuntary staff reductions. USDA’s service center agencies kept track of 

how many employees took advantage of the incentives and how much 

money was saved. They also reported some additional information to the 

department on their results. For example, NRCS reported that its 

Establish an Evaluation 

System
 

Page 34 GAO-14-288 Department of Agriculture

incentives, offered in conjunction with its fiscal year 2012 office closures, 

helped the agency manage any negative impact of the closures and lower 

the total number of employees needing placement in other positions, and 

RD reported to USDA that the use of buyout and early retirement 

incentives helped achieve budget savings and that enhanced training 

may be needed to offset the loss of institutional knowledge created by 

departing employees. However, the agencies did not conduct a broader 

evaluation of their use of the incentives or report on the extent to which 

the buyout and early retirement incentives met other stated goals to 

support their missions. For example, FSA officials told us that they did not 

evaluate how the incentives impacted nonbudgetary goals cited in their 

agency’s request to use buyout and early retirement incentives, such as 

improving supervisory ratios. NRCS officials told us that they did not 

establish an evaluation system due to lack of time, but they 

acknowledged that such information would be helpful in understanding, 

among other things, the impact such incentives have on employees. In 

addition, because the agencies did not examine, for example, the length 

of service of employees who accepted incentives, how the savings 

generated by the incentives compared with other options, such as 

Reductions in Force, or what effects the use of incentives had on stated 

workforce reshaping goals, agency managers cannot use resulting 

information to inform future decisions.

When issuing its policy on supervisory ratios, USDA has taken important 

steps to consider how these ratios relate to the effective management of 

human capital. However, because this policy established a uniform 

supervisory ratio target for all agencies across the department, it did not 

align with OPM guidance on supervisory ratios. Adopting OPM’s guidance 

would allow the service center agencies to identify supervisory ratio 

targets that would support their unique missions, based on a documented 

analysis of their customer needs and workload distribution. Further, 

federal internal control standards state that managers should exercise 

control to achieve reasonable assurance that the objectives of their 

agency are being achieved, but USDA did not exercise control to ensure 

that the service center agencies followed its guidance on calculating 

supervisory ratios. USDA has not communicated the guidance on how to 

calculate supervisory ratios to the service center agencies since 2010. 

Ensuring that the service center agencies provide comparable information

on supervisory ratios would allow the department to use this information 

to help determine whether its human capital objectives are being met.

Conclusions
 

Page 35 GAO-14-288 Department of Agriculture

Facing fiscal year 2012 budget realities, USDA’s service center agencies 

needed to make difficult decisions to close field offices. In doing so, the 

agencies followed or partially followed many leading practices associated 

with effective implementation of office closures. Nevertheless, given 

ongoing budget pressures, agencies may again face similar situations. 

USDA’s policy governing organizational changes does not direct agencies 

to fully follow leading practices such as presenting all elements of a 

business-case or cost-benefit analysis or measuring progress toward 

stated goals. Following these practices could improve transparency and 

decision making while also helping the agencies meet internal control 

standards in support of their missions. Specifically, asking agencies to 

follow the leading practice of presenting a business-case or cost-benefit 

analysis could help agencies clearly communicate the rationale for their 

decisions to all stakeholders and show that they are aiming to make 

effective use of public funds as they work to implement their missions. It 

could also help them meet internal control standards to document key 

decisions. Similarly, asking agencies to follow the leading practice of 

measuring progress toward goals could help agencies meet internal 

control standards to establish and use performance measures, while also 

helping them to make any needed midcourse corrections, improve 

effectiveness following office closures, or inform stakeholders on their 

progress or outcomes.

USDA’s service center agencies also made important decisions to reduce 

staff in fiscal year 2012 by using buyout and early retirement incentives 

and, in doing so, they followed most leading practices associated with the 

effective use of such tools. However, ongoing budget constraints may 

again require considering the use of these incentives. In such instances, 

FSA and RD might find it easier to avoid unintended shortages or 

imbalances of employees with certain skills that could hamper 

accomplishment of their missions if they clearly linked their buyout and 

early retirement incentives to their workforce reshaping goals or overall 

strategic goals. In addition, establishing and using a system to identify 

and evaluate relevant data on use of the incentives would allow USDA’s 

service center agencies to better understand whether the incentives they 

offer are the best use of their limited resources, which could help to 

inform future actions in support of their missions.
 

Page 36 GAO-14-288 Department of Agriculture

We are making the following five recommendations to the Secretary of 

Agriculture:

To ensure appropriate levels of employees’ supervision and guidance for 

the workforces of USDA’s service center agencies, we recommend that 

the Secretary of Agriculture, through the Chief Human Capital Officer, 

take the following two actions:

• Consistent with OPM guidance, revise departmental policy targeting a 

uniform supervisory ratio so that the service center agencies can 

identify appropriate supervisory ratios based on a documented 

analysis of their specific customer needs and workload distribution.

• Consistent with federal internal control standards, communicate to the 

service center agencies the departmental guidance for calculating 

supervisory ratios and ensure its use.

To help USDA’s service center agencies effectively implement office 

closures and meet internal control standards, we recommend that the 

Secretary take action to amend USDA’s policy on organizational changes 

to include such leading practices as presenting a business-case or costbenefit analysis and using the change management practice of measuring 

progress toward stated goals.

To improve the use of buyout or early retirement incentives, we 

recommend that the Secretary of Agriculture direct its service center 

agencies to take the following two actions:

• FSA and RD to document clear links between their buyout and early 

retirement incentives and their reshaping or overall strategic goals.

• FSA, NRCS, and RD to establish a system for identifying and 

evaluating relevant data on buyout and early retirement incentive 

recipients.

We provided USDA with a draft of this report for comment. USDA 

provided written comments, which are summarized below and reproduced 

in appendix IV. In its comment letter, USDA generally agreed with some 

of the findings and disagreed with one finding and recommendation. 

USDA did not explicitly comment on other recommendations.

USDA generally agreed with our findings on the use of leading practices 

when closing offices and reducing staff in fiscal year 2012, and did not 

comment specifically on our associated recommendations. USDA stated 

Recommendations for 

Executive Action

Agency Comments 

and Our Evaluation
 

Page 37 GAO-14-288 Department of Agriculture

that actions taken by its service center agencies to close offices and 

reduce staff were in response to significant budget cuts and needed to be 

implemented in a relatively short time frame. USDA further stated that the 

agencies followed requirements in taking these actions, and did an 

excellent job linking their workforce decisions to mission. We adjusted our 

report’s title to reflect that we believe USDA’s workforce decisions could 

benefit from implementation of our findings and recommendations.

USDA did not agree with our finding that USDA’s policy on supervisory 

ratios did not align with OPM guidance and our associated 

recommendation that USDA revise this policy. USDA stated that OPM’s 

guidance on supervisory ratios is written purposefully broad and that the 

policy allows the department to hold supervisors and managers 

accountable for the responsible stewardship of resources. We agree that 

OPM’s guidance is broad and that it allows agencies discretion. As we 

reported, it also states that an effective balance of supervisory and nonsupervisory positions is achieved when agencies analyze their customer 

needs and workload distribution to support their missions. USDA was not 

able to provide us with evidence that its policy targeting a ratio of 1 

supervisor to at least 9 employees was based on such an analysis or on 

other information suggesting that a uniform target was appropriate for all 

of the service center agencies given their diverse missions, customer 

needs, and workload distribution. Further, USDA stated that its policy 

allows agencies to document the reasons for instances in which the 

supervisory ratio does not meet the departmental target of 1 supervisor to 

at least 9 employees by considering factors such as job complexity and 

diversity of assigned functions. However, documenting such deviations 

requires that USDA’s agencies show why it is appropriate for them to 

deviate from a department-wide policy as opposed to factoring such 

analysis into their supervisory ratios initially. Finally, USDA notes that the 

policy was effectively communicated to all agencies and staff offices, 

along with supplemental guidance on how to calculate supervisor-toemployee ratios. During our review, USDA officials provided us a 

guidance document on how to calculate supervisory ratios and said that 

they had provided it to the mission areas’ human resources directors in 

2010. However, as discussed in our report, USDA officials could not 

provide documentation that the guidance was communicated to the 

service center agencies, and none of the service center agencies 

followed this guidance. Therefore, we continue to believe that USDA 

needs to revise departmental policy targeting a uniform supervisory ratio, 

communicate to the service center agencies guidance for calculating 

supervisory ratios, and ensure its use.
 

Page 38 GAO-14-288 Department of Agriculture

As agreed with your office, unless you publicly announce the contents of 

this report earlier, we plan no further distribution until 30 days from the 

report date. At that time, we will send copies to the Secretary of 

Agriculture, the Director of the Office of Personnel Management, and the 

appropriate congressional committees. In addition, this report will be

available at no charge on the GAO website at http://www.gao.gov.

If you or your staff members have any questions about this report, please 

contact me at (202) 512-3841 or fennella@gao.gov. Contact points for 

our Offices of Congressional Relations and Public Affairs may be found 

on the last page of this report. Key contributors to this report are listed in 

appendix V.

Sincerely yours,

Anne-Marie Fennell

Director, Natural Resources and Environment
Appendix I: Objectives, Scope, and 

Methodology

Page 39 GAO-14-288 Department of Agriculture

This report examines: (1) how the workforces of USDA’s service center 

agencies changed from fiscal year 2003 to fiscal year 2012, (2) the extent 

to which USDA’s policy on supervisory ratios aligned with Office of 

Personnel Management (OPM) guidance in fiscal year 2012, and (3) the 

extent to which USDA’s service center agencies followed leading 

practices when closing offices and reducing staff in fiscal year 2012.

We chose the three USDA service center agencies—the Farm Service 

Agency (FSA), Natural Resources Conservation Service (NRCS), and 

Rural Development (RD)—because, of the eight USDA agencies that had 

announced they would close offices and programs in fiscal year 2012,1

these agencies had the largest staffing level percent reductions.2 We 

chose to report workforce data for 10 years, starting with fiscal year 2003, 

because this period (1) provided a historical context for the changes that 

occurred in fiscal year 2012 and (2) encompassed the agencies’ 

operations under two farm bills: the Farm Security and Rural Investment 

Act of 20023 and the Food, Conservation, and Energy Act of 2008 (2008 

Farm Bill).4

To determine how the workforces of USDA’s service center agencies 

changed from fiscal year 2003 to fiscal year 2012, we analyzed workforce

data from OPM’s Enterprise Human Resources Integration database and 

USDA’s National Finance Center; reviewed available reports, plans, and 

guidance from OPM and USDA related to human capital management; 

and interviewed OPM and USDA officials.5 Using the OPM and USDA 

data, we determined the changes in the workforces of USDA’s service 

center agencies, including the General Schedule, Senior Executive 

 

1

In addition to the three service center agencies, the other five agencies that closed 

offices or programs in fiscal year 2012 include the Agricultural Research Service, the 

Animal and Plant Health Inspection Service, the Food, Nutrition and Consumer Services, 

the Food Safety and Inspection Service, and the Foreign Agricultural Service.

2

Staffing levels refer to the full-time equivalent data presented in agency budget 

documents. Full-time equivalent refers to the total number of regular straight-time (i.e., not 

including overtime or holiday hours) worked by employees divided by the number of 

compensable hours applicable to each fiscal year.

3

Pub. L. No. 107-171 (2002).

4

Pub. L. No. 110-246, tit. XIV, § 14212 (2008).

5

Data from the Enterprise Human Resources Integration database represent a snapshot 

of employees onboard as of September 30 in each fiscal year.

Appendix I: Objectives, Scope, and 

Methodology
Appendix I: Objectives, Scope, and 

Methodology

Page 40 GAO-14-288 Department of Agriculture

Service, as well as county office employees, who are not federal 

employees and are, therefore, not captured in OPM’s database. For 

county office employees, we obtained their workforce data from USDA 

directly. Our analysis focused on career permanent employees on a fullor part-time year-round schedule. We generally excluded temporary and 

term-limited employees and schedules other than full- and part-time (such 

as intermittent or seasonal) because these employees are generally not 

eligible for civil service benefits and represent a more transient workforce. 

When reporting data on employees by location, we defined headquarters 

operations to include the Washington, D.C., locality pay area and other 

duty stations that are considered to be part of the headquarters 

operations. For FSA, these locations include Kansas City, Missouri; St. 

Louis, Missouri; and Salt Lake City, Utah. For NRCS, these include Fort 

Collins, Colorado; Fort Worth, Texas; Greensboro, North Carolina; 

Lincoln, Nebraska; Little Rock, Arkansas; and Portland, Oregon. For RD, 

this includes St. Louis, Missouri. For the purpose of this report, 

employees in all other duty stations are considered to be in field 

locations.6 We calculated supervisory ratios by comparing the number of 

supervisors or managers with the number of nonsupervisors or 

managers, as defined by OPM, in accordance with the USDA’s Office of 

Human Resources Management’s guidance.7 We did not independently 

check the agencies’ coding of supervisors.

We completed additional analyses on the workforces of USDA’s service 

center agencies at the end of fiscal year 2012 because, during that year, 

USDA announced the Blueprint for Stronger Service, an initiative that 

included office closures and resulted, in some cases, in the offerings of 

buyout and early retirement incentives. Such actions could affect the size 

and composition of the workforces of USDA’s service center agencies. 

 

6

This method of using the locality pay and duty stations of employees for this purpose 

may have resulted in some field locations’ employees being considered to be part of the 

headquarters operations. We believe that the number of employees who may have been 

misclassified is sufficiently small as to not materially affect our result.

7

OPM, The Guide to Data Standards, Part A: Human Resources, Update 12 (Washington, 

D.C.: May 1, 2013). Supervisory code 2 was used to identify supervisors or managers. 

Positions with this code are defined as those that require the exercise of supervisory or 

managerial responsibilities that meet, at least, the minimum requirements for application 

of the General Schedule Supervisory Guide or similar standards of minimum supervisory 

responsibility specified by position classification standards or other directives of the 

applicable pay schedule or system. This is also the code most commonly used for Senior 

Executive Service positions.
Appendix I: Objectives, Scope, and 

Methodology

Page 41 GAO-14-288 Department of Agriculture

We analyzed USDA’s service center agencies’ ethnicity and race, gender, 

pay grade levels, mission-critical occupations, length of federal service, 

and retirement eligibility. We used OPM’s standard categories for our 

analysis of ethnicity and race and gender.8 Our analysis of pay grade 

levels included employees on the General Schedule, as well as county 

office employees, whose grade levels are comparable to the General 

Schedule pay plan. We grouped grade levels into three categories; the 

middle range covers the median grades of NRCS’s and RD’s workforces, 

as well as the FSA headquarters workforce. To analyze mission-critical 

occupations, we obtained a list of these occupational series from the 

agencies’ workforce plans or agency officials.9 To provide more detailed 

information about mission-critical occupations, we obtained position 

descriptions from USDA’s service center agencies. We grouped length of 

federal service into five categories based on typical attrition patterns. To 

determine the current and projected retirement eligibility, we used 

employees’ age at hire, federal government service start date, birth date, 

and retirement plan coverage to calculate the date they would become 

eligible for voluntary retirement with an unreduced annuity.

We took several steps to ensure the reliability of the data and analytical 

process. We discussed the reliability of the USDA data with 

knowledgeable officials and collected additional data reliability information 

on both OPM and USDA data through interviews with FSA, NRCS, and 

RD. In our analysis of OPM and USDA data, we checked for outliers or 

obvious errors and followed up with USDA when such issues were 

identified. In addition, where we identified anomalies or significant change 

in trends in our detailed analysis of the size of the workforces and 

supervisory ratios, we corroborated these findings with agency human 

capital staff and published reports. Lastly, the programming code for this 

analysis was reviewed by an independent specialist to verify its technical 

and logical accuracy.

To determine the extent to which USDA policy on supervisory ratios 

aligned with OPM guidance in fiscal year 2012, we reviewed OPM 

guidance on its Human Capital Assessment and Accountability 

 

8

We used OPM’s ethnicity and race categories, applicable to employees acceding on or 

after January 2006, for all employees for consistency.

9

For the purpose of this report, we used OPM’s standard titles for mission-critical 

occupations, rather than agency-specific titles. 
Appendix I: Objectives, Scope, and 

Methodology

Page 42 GAO-14-288 Department of Agriculture

Framework and compared it with USDA’s policy on supervisory ratios; 

analyzed workforce data from OPM and USDA databases on supervisory 

ratios; reviewed reports from USDA’s service center agencies on their 

supervisory ratios and compared them with USDA guidance on 

calculating supervisory ratios, as well as standards for internal control in 

the federal government; and interviewed officials from OPM, USDA, and 

USDA’s service center agencies.10

To determine the extent to which USDA’s service center agencies 

followed leading practices to close offices and reduce staff in fiscal year 

2012, we identified leading practices for both office closures and staff 

reductions through the use of buyout and early retirement incentives. For 

office closures, we reviewed previous GAO work on consolidating 

physical infrastructure to identify four leading practices for successful 

office closures.11 These include: (1) identify and agree upon goals, (2) 

present a business-case or cost-benefit analysis, (3) identify stakeholders 

and develop a two-way communications strategy, and (4) implement 

consolidations using change management practices. For staff reductions, 

we reviewed provisions of the Chief Human Capital Officers Act of 2002 

that revise the use of voluntary early retirement authority and voluntary 

separation incentive payments, regulations and guidance from OPM on 

the use of buyout and early retirement incentives, and leading practices 

from previous GAO work to identify six leading practices for implementing 

buyout and early retirement incentives.12 These include: (1) identify 

reshaping goals, (2) develop strategies that fully consider alternative 

methods, (3) demonstrate a clear linkage to workforce reshaping and 

overarching strategic goals, (4) consider employees’ needs, (5) develop a 

communications strategy early in the process, and (6) establish an 

evaluation system. We also reviewed standards for internal control in the 

federal government.13 We gathered information on agency actions by 

collecting documentation and interviewing officials from FSA, NRCS, and 

RD. We also interviewed representatives of unions and employee 

associations at FSA and RD. We assessed each agency’s reported 

actions against the identified leading practices to determine the extent to 

 

10GAO/AIMD-00-21.3.1.

11GAO-12-542. 

12GAO-06-324. 

13GAO/AIMD-00-21.3.1.
Appendix I: Objectives, Scope, and 

Methodology

Page 43 GAO-14-288 Department of Agriculture

which each agency’s actions aligned with these practices. Because the 

leading practices are not requirements, we did not perform a compliance 

review. To communicate the results of our review, we used the terms, 

“followed,” “partially followed,” and “did not follow” to reflect in plain 

language the extent to which each agency’s actions aligned with identified 

leading practices. A determination of “followed” means that the agency 

provided evidence that it had taken major actions in alignment with that 

leading practice. A determination of “partially followed” means that the 

agency provided evidence that it had taken some actions in alignment 

with that leading practice. A determination of “did not follow” means that 

the agency did not provide evidence that it had taken any actions in 

alignment with that leading practice. To determine the number and type of 

service center agency staff members who accepted buyout and early 

retirement incentives, we used information provided by each agency and 

analyzed workforce data from OPM’s Enterprise Human Resources 

Integration database. Eligibility for retirement or early retirement is based 

on age at hire, birth date, service computation date, and retirement plan. 

Because the OPM data we have did not include the specific day of the 

month for each employee’s service computation date and birthday, these 

results may be off by up to 1 month.

To review FSA’s fiscal year 2012 decisions related to office closures and 

requirements in the 2008 Farm Bill, we compared provisions in the 2008 

Farm Bill with information from FSA on each office that closed as a result 

of the USDA announcement made in fiscal year 2012 related to: (1) 

location and distance from the nearest FSA office;14 (2) the number and 

type of employees;15 (3) the location and date of public meetings; (4) the 

dates of congressional notifications; and (5) the actual date closed. To 

determine the locations and distances of each closed office, we used 

USDA-provided addresses to independently calculate the latitude and 

longitude for each street address of each closed office and its next 

closest office as identified by USDA. Using these addresses, we 

independently calculated the distances between the closed and nearest 

offices using our calculated latitude and longitude. In instances where 

 

14We did not independently verify whether other FSA offices that were less than 20 miles 

from another FSA office and that had two or fewer full-time permanent employees 

remained open.

15We did not independently verify whether other FSA offices with no employees remained 

open. 
Appendix I: Objectives, Scope, and 

Methodology

Page 44 GAO-14-288 Department of Agriculture

automated tools could not determine a specific location for a given 

address, our analysis relied on manual determination of geocoordinates. 

We did not assess whether FSA complied with the 2008 Farm Bill’s office 

closure provisions.

We conducted this performance audit from October 2012 to March 2014 

in accordance with generally accepted government auditing standards. 

Those standards require that we plan and perform the audit to obtain 

sufficient, appropriate evidence to provide a reasonable basis for our 

findings and conclusions based on our audit objectives. We believe that 

the evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objectives.
Appendix II: Additional Information on the 

Workforces of USDA’s Service Center 

Agencies in Fiscal Year 2012

Page 45 GAO-14-288 Department of Agriculture

In fiscal year 2012, the headquarters and field workforces of the USDA 

service center agencies were different from each other with respect to 

ethnicity, race, gender, and pay grade.1 As it relates to race and ethnicity, 

workforces were more diverse in headquarters operations than field 

locations of the service center agencies. In terms of pay grades, a greater 

proportion of the workforces in headquarters operations were at pay 

grades 13-15 than was the case in field locations of the service center 

agencies. USDA and its service center agencies identified a number of 

mission-critical occupations, which applied across their headquarters 

operations and field locations. Across all locations, over 40 percent of the 

workforces of USDA’s service center agencies had 20 or more years of 

service. In general, a higher proportion of supervisors was eligible, or 

projected to become eligible, for retirement compared with all employees 

of USDA’s service center agencies.

In fiscal year 2012, the career permanent workforces of USDA’s service 

center agencies’ headquarters operations were more diverse than their 

field locations. As shown in figure 7, white employees constituted about 

one-half or two-thirds of the headquarters operations of the workforces of 

the three agencies but about 80 percent or more of their field locations’ 

workforces. In general, African American or black employees made up 

the second largest percentage of the workforce in the service center 

agencies’ headquarters operations and field locations. For all of the 

service center agencies, they made up a larger proportion of the 

workforces in headquarters operations than those in field locations.

 

1

All analyses of the workforces in this section were done for career permanent employees 

on full- and part-time year-round schedules.

Appendix II: Additional Information on the 

Workforces of USDA’s Service Center 

Agencies in Fiscal Year 2012

Composition of the 

Workforces of USDA’s 

Service Center Agencies 

by Ethnicity, Race, and 

Gender in Fiscal Year 

2012
Appendix II: Additional Information on the 

Workforces of USDA’s Service Center 

Agencies in Fiscal Year 2012

Page 46 GAO-14-288 Department of Agriculture

Figure 7: Ethnicity and Race of the Career Permanent Workforces of USDA’s Service Center Agencies by Location in Fiscal 

Year 2012

Note: This figure shows the results for employees on full- and part-time year-round schedules.

a

”All other” includes American Indian or Alaska Native, Asian, Native Hawaiian or Other Pacific 

Islander, or employees who identified themselves as being of more than one ethnicity or race.

With respect to gender, women comprised the majority of the career 

permanent workforces of Farm Service Agency (FSA) and Rural 

Development (RD) (72 percent and 65 percent, respectively), and about 

35 percent of the career permanent workforce of Natural Resources 

Conservation Service (NRCS). However, women made up a smaller 

proportion of supervisors than their share of the workforces of all three 

service center agencies—making up about 36 percent of supervisors at 

FSA, 28 percent at NRCS, and 39 percent at RD. With respect to 

women’s share of the workforce in headquarters operations as compared 

with field locations, the service center agencies differed from each other. 

At FSA, women made up a smaller portion of the headquarters operations 

workforce as compared with the field locations workforce (58 percent and 

74 percent, respectively). At NRCS, women made up a higher share of 

the workforce at headquarters operations compared with the field 

locations (44 percent and 34 percent, respectively). At RD, women’s 

share of the workforce was approximately the same at both headquarters 

operations and field locations (67 percent and 64 percent, respectively).
Appendix II: Additional Information on the 

Workforces of USDA’s Service Center 

Agencies in Fiscal Year 2012

Page 47 GAO-14-288 Department of Agriculture

In fiscal year 2012, a greater proportion of the career permanent 

workforces of USDA’s service center agencies in headquarters operations 

were at pay grades 13-15 than those in field locations (as shown in fig. 8). 

In field locations, the majority of FSA employees were in pay grades 1-9;2

in NRCS and RD, more employees were at pay grades 10-12 than other 

grades.

Figure 8: Grades of the Career Permanent Workforces of USDA’s Service Center Agencies by Location in Fiscal Year 2012

Note: This figure shows the results for employees on full- and part-time year-round schedules. The 

Farm Service Agency figure for field locations combines the levels of the General Schedule and 

county office pay plans. All other figures provide the grade levels for the General Schedule pay plan.

a

”Other” include other types of pay plans such as Senior Level (SL).

In fiscal year 2012, USDA designated three mission-critical occupations 

(MCO) as its overall departmental MCOs based on considerations related

to recruitment and retention challenges. They are (1) Human Resources 

Management (0201), (2) Contracting (1102), and (3) Informational 

Technology Management (2210). In addition, in fiscal year 2012, in 

response to USDA’s request, each service center agency reported 

between three and five MCOs to USDA as listed below.

 

2

For the purpose of this report, we combined the General Schedule and county office 

employees when determining the pay grades of the FSA workforce.

Composition of the 

Workforces of USDA’s 

Service Center Agencies 

by Grade in Fiscal Year 

2012

Mission-Critical 

Occupations of USDA and 

Its Service Center 

Agencies in Fiscal Year 

2012
Appendix II: Additional Information on the 

Workforces of USDA’s Service Center 

Agencies in Fiscal Year 2012

Page 48 GAO-14-288 Department of Agriculture

In fiscal year 2012, FSA reported five MCOs to USDA.3 Approximately 37 

percent of employees in headquarters operations and 92 percent of 

employees in field locations were classified in one of these occupations. 

All of these occupations are classified as administrative and 

management. Table 2 lists the MCOs for FSA as reported to USDA in 

fiscal year 2012, including occupation codes, titles, and examples of 

position descriptions.

Table 2: The Farm Service Agency’s (FSA) Mission-Critical Occupations’ Series, Titles, and Examples from Position 

Descriptions

Occupation 

series Occupation title Examples from FSA position descriptions a

0341 Administrative Officer Assistant to the state executive director (SED) and staff adviser to the SED, state FSA 

committee, district directors, county executive directors, and farm loan managers on 

administrative management issues. Plans and manages the administrative management 

program for a state office and its subordinate county offices, including management 

analysis, personnel management, automation, support services, budget, and financial 

management. 

1101 General Business and 

Industryb County executive director who directs and manages FSA program and administrative  operations for one or more counties. 

1102 Contracting Contract specialist who provides procurement services in support of agricultural 

commodity and commodity-related services acquisitions. 

1165 Loan Specialist Supervisory loan specialist who manages and directs the farm loan programs 

administered in one or more USDA service centers. Supervises and directs the work of 

subordinate staff responsible for making, servicing, and liquidating loans under FSA farm 

loan authorities. 

2210 Information Technology 

Management 

Business applications developer who is responsible for the design, development, and 

maintenance of complex information systems. Provides technical assistance to various 

levels of administrative officials, operating personnel, and other information technology 

specialists. 

Sources: GAO analysis of Office of Personnel Management (OPM), USDA, and FSA data.

a

For the General Schedule, OPM defines the titles, duties, and qualifications of classes of positions. 

Agencies may classify multiple positions under a single OPM-defined series. For example, FSA uses 

the General Business and Industry series (1101) for agency-specific positions such as a district 

director and program technician. For the purpose of this report, we used the standard OPM-defined 

titles.

b

 

3

In addition to these five, FSA officials told us that, in fiscal year 2010, the agency 

identified six additional occupations that it considered to be mission critical in fiscal year 

2012, which were also reported in its fiscal year 2014 workforce plan. These included 

Human Resources Management (0201), Accounting (0510), Budget Analysis (0560), 

Agricultural Program Specialist (1145), Agricultural Marketing (1146), and Agricultural 

Warehouse Inspection (1850). 

This occupation may also be categorized as clerical and administrative support.

Farm Service Agency
Appendix II: Additional Information on the 

Workforces of USDA’s Service Center 

Agencies in Fiscal Year 2012

Page 49 GAO-14-288 Department of Agriculture

In fiscal year 2012, NRCS reported three MCOs to USDA.4 Approximately 

21 percent of employees in headquarters operations and 49 percent of 

employees in field locations were classified in one of these MCOs. All of 

these MCOs are classified as professional and scientific occupations. 

Table 3 lists the MCOs for NRCS as reported to USDA in fiscal year 

2012, including occupation codes, titles, and examples of position 

descriptions.

Table 3: The Natural Resources Conservation Service’s (NRCS) Mission-Critical Occupations’ Series, Titles, and Examples 

from Position Descriptions

Occupation 

series Occupation title Examples from NRCS position descriptions a

0401 General Natural Resources 

Management and Biological 

Sciences 

Assistant state conservationist for field operations, providing supervision, guidance, 

and assistance to all field offices and managerial units in the designated state.

0457

b

Soil Conservation District conservationist who assists the soil and water conservation district within 

one or more counties in the development of a comprehensive natural resources 

conservation program.

0810

c

Civil Engineering Area, zone, or state engineer who is responsible for providing technical guidance 

and leadership in the overall planning, design, installation, and maintenance of the 

engineering phases of soil and water conservation practices, as well as watershed 

flood protection programs.

Sources: GAO analysis of Office of Personnel Management (OPM), USDA, and NRCS data.

a

For the General Schedule, OPM defines the titles, duties, and qualifications of classes of positions. 

Agencies may classify multiple positions under a single OPM-defined series. For example, NRCS 

uses the Soil Conservation series (0457) for agency-specific positions such as district conservationist 

and assistant state conservationist for field operations. For the purpose of this report, we used the 

standard OPM-defined titles.

b

This is an interdisciplinary position. This position may be classified under the 0457 occupation series, 

depending on the qualification of the employee.

c

 

4

NRCS also reported an additional 16 MCOs in its workforce plan, which applied in fiscal 

year 2012. These occupations include: Economist (0110), Human Resources 

Management (0201), Rangeland Management (0454), Soil Conservation Technician 

(0458), Forestry (0460), Soil Science (0470), Agronomy (0471), Accounting (0510), 

Budget Analysis (0560), Engineering Technician (0802), Agricultural Engineering (0890), 

General Business and Industry (1101), Contracting (1102), Public Affairs (1035), 

Cartography (1370), and Information Technology Management (2210).

Soil and water conservation districts are legal subdivisions of a state government with an elected 

governing body, which develops and implements soil and water conservation programs within a 

certain area, usually coinciding with county lines.

Natural Resources 

Conservation Service
Appendix II: Additional Information on the 

Workforces of USDA’s Service Center 

Agencies in Fiscal Year 2012

Page 50 GAO-14-288 Department of Agriculture

In fiscal year 2012, RD reported five MCOs to USDA.5 Approximately 61 

percent of employees in headquarters operations and 79 percent of 

employees in field locations were classified in one of these MCOs. All of 

RD’s reported MCOs, except for Accounting (0510), which is classified as 

a professional and scientific occupation, are classified as administrative 

and management. Table 4 lists the MCOs for RD as reported to USDA in 

fiscal year 2012, including occupation codes, titles, and examples of 

position descriptions.

Table 4: Rural Development’s (RD) Mission-Critical Occupations’ Series, Titles, and Examples from Position Descriptions 

Occupation 

series Occupation title Examples from RD position descriptions a

0510 Accounting Senior accountant who works in RD’s cash management branch to help develop and 

modify disbursement accounting systems.

1101 General Business and 

Industryb Processor who reviews, verifies, and prepares documentation related to post- accelerations, loss avoidance, foreclosures, and curing defaults. 

1102 Contracting Senior contract specialist who independently develops contract negotiation plans, 

administers contracts, and develops milestone plans for assigned work. Advises 

program officials in procurement planning and methods.

1165 Loan Specialist Senior loan specialist who administers, delivers, and evaluates a state’s multifamily and 

single-family housing loan and grant programs. 

2210 Information Technology Information technology specialist in operating systems who supports the collection of 

metrics used in the monitoring and evaluation of information technology resources such 

as the National Information Technology Center mainframe. Analyzes data on capacity 

and performance and makes recommendations for hardware refreshments and 

enhancements.

Sources: GAO analysis of Office of Personnel Management (OPM), USDA, and RD data.

a

For the General Schedule, OPM defines the titles, duties, and qualifications of classes of positions. 

Agencies may classify multiple positions under a single OPM-defined series. For example, RD uses 

the General Business and Industry series (1101) for agency-specific positions such as processor and 

area technician. For the purpose of this report, we used the standard OPM-defined titles.

b

This occupation may also be categorized as clerical and administrative support.

 

5

RD officials also told us that they considered all of USDA’s mission-critical occupations to 

apply to their mission area, which would include, in addition to the five reported to USDA 

in fiscal year 2012, Human Resources Management (0201). 

Rural Development
Appendix II: Additional Information on the 

Workforces of USDA’s Service Center 

Agencies in Fiscal Year 2012

Page 51 GAO-14-288 Department of Agriculture

The proportion of the career permanent workforces of USDA’s service 

center agencies with 20 or more years of federal service in fiscal year 

2012 was over 50 percent at FSA, over 40 percent at NRCS, and over 45 

percent at RD (as shown in fig. 9). Employees may be eligible for early 

retirement incentives once they have 20 or more years of service and are 

over the age of 50 or have 25 or more years of service regardless of age. 

The mean length of service of FSA employees was 19 years, for NRCS it 

was 16 years, and for RD it was 18 years. At FSA and NRCS, employees 

in headquarters operations have, on average, more federal service years 

than those in field locations. At FSA, the mean length of federal service 

for the headquarters operations workforce was 21 years and, for the field 

locations, it was 18 years. Similarly, at NRCS, the mean length of service 

for the headquarters operations workforce was 19 years, and for the field 

locations, it was 16 years. At RD, the headquarters operations and field 

locations workforces had the same mean length of service of 18 years.

Composition of the 

Workforces of USDA’s 

Service Center Agencies 

by Length of Service in 

Fiscal Year 2012
Appendix II: Additional Information on the 

Workforces of USDA’s Service Center 

Agencies in Fiscal Year 2012

Page 52 GAO-14-288 Department of Agriculture

Figure 9: Percentage of the Career Permanent Workforces of USDA’s Service 

Center Agencies in Length of Federal Service Categories in Fiscal Year 2012

Note: This figure shows the results for employees on full- and part-time year-round schedules.
Appendix II: Additional Information on the 

Workforces of USDA’s Service Center 

Agencies in Fiscal Year 2012

Page 53 GAO-14-288 Department of Agriculture

About 15 percent of the career permanent workforces of USDA’s service 

center agencies were eligible to retire in fiscal year 2012, as shown in 

figure 10.6 For supervisors, the proportion was higher: at FSA it was 19 

percent, at NRCS it was 24 percent, and at RD it was 22 percent. Over 

the next 5 years, an additional 17 percent or more of the workforces of 

each of the service center agencies and 25 percent or more of their 

supervisors will become retirement-eligible for the first time.

Figure 10: Percentage of the Career Permanent Workforces of USDA’s Service Center Agencies Eligible to Retire in Fiscal 

Year 2012 and Those Projected to Become Eligible for Retirement in the Next 5 Years

Note: This figure shows the results for employees on full- and part-time year-round schedules as of 

September 30, 2012.

 

6

This analysis was done using data as of September 30, 2012. To determine the 

proportion of employees eligible to retire, we only considered those eligible for voluntary 

retirement with unreduced annuity.

Current and Projected 

Retirement Eligibility of the 

Workforces of USDA’s 

Service Center Agencies 

in Fiscal Year 2012
Appendix III: Section 14212(b) of the Food, 

Conservation, and Energy Act of 2008 and the 

Farm Service Agency’s Office Closures 

Initiated in Fiscal Year 2012

Page 54 GAO-14-288 Department of Agriculture

Section 14212(b) of the Food, Conservation, and Energy Act of 2008 

(2008 Farm Bill) prescribes an order for closure of Farm Service Agency 

(FSA) offices after June 18, 2010, and requires public and congressional 

notification of proposed closures.1 Specifically, under section 14212(b), if 

the Secretary of Agriculture closes FSA offices after June 18, 2010, 

offices that have two or fewer permanent full-time employees and are 

located less than 20 miles from another FSA office are required, to the 

maximum extent practicable, to be closed before closing offices located 

more than 20 miles from another FSA office. In addition, the Secretary 

must (1) hold a public meeting in the county where the office is located 

within 30 days of proposing its closure and (2) notify the relevant 

congressional committees and delegations of a proposed office closure 

after the public meetings and not less than 90 days before approving the 

office’s closure.

On January 9, 2012, the Secretary of Agriculture initially proposed closing 

131 FSA offices.2 The list included both offices with two or fewer 

permanent full-time employees that were located less than 20 miles from 

another FSA office and offices located more than 20 miles from another 

FSA office. The offices located more than 20 miles from another office 

had no employees. To determine the number of employees in each office, 

FSA officials told us that they counted permanent, full-time General 

Schedule or county office employees. State-level and temporary 

employees did not count toward the total number of employees in an 

office. To determine the distances between offices, FSA officials said they 

used a mapping software program to determine whether or not an office 

was located within 20 miles of another FSA office. FSA officials stated 

that they calculated the shortest distance between offices rather than 

driving distance. However, according to FSA officials, their software 

defaulted to the center of the zip code if a street could not be found, so 

FSA used a proxy in those instances rather than an actual address.3

 

1

Pub. L. No. 110-246, tit. XIV, § 14212(b) (2008).

2

In addition, FSA closed an office in August, 2010. FSA did not provide us with information 

on the process used to close this office.

3

We did not verify the number of addresses FSA was unable to locate; however, our 

analysis required manually matching addresses to locations for 17 offices. 

Appendix III: Section 14212(b) of the Food, 

Conservation, and Energy Act of 2008 and the 

Farm Service Agency’s Office Closures 

Initiated in Fiscal Year 2012

FSA Proposed Offices for 

Closure Based on Staffing 

and Distance from Other 

FSA Offices
Appendix III: Section 14212(b) of the Food, 

Conservation, and Energy Act of 2008 and the 

Farm Service Agency’s Office Closures 

Initiated in Fiscal Year 2012

Page 55 GAO-14-288 Department of Agriculture

FSA held public meetings and accepted comments on the proposed 

closures. Between January 19, 2012, and February 8, 2012—within 30 

days of proposing the office closures—FSA held a public meeting in each 

county where the offices proposed for closure were located. FSA officials 

told us that they publicized meetings through newspaper advertisements 

and mailers to agricultural producers, among others. During these public 

meetings, FSA recorded public comments, and officials said that 

concerns were incorporated into their office closure decisions. For 

example, public meeting participants said that FSA program participation 

would decline as a result of the office closures, particularly among 

beginning, elderly, and disadvantaged producers who may endure extra 

hardships from traveling greater distances to the next-closest FSA office.4

Participants also said that the distances calculated by FSA did not 

accurately reflect the amount of time it takes producers to reach FSA 

offices. As a result of public meeting participant concerns, FSA officials 

told us that in the event that producers could not reach an FSA office—for 

example, if producers were elderly or disabled—FSA would send an FSA 

employee to meet them at more convenient locations. In addition, FSA 

accepted written comments for up to 10 days after the date of the meeting 

from those who could not attend in person.

FSA provided us with documentation of notifications sent to congressional 

committees and members of the proposed office closures on February 

27, 2012. The scope of our review did not include an assessment of 

whether the notifications met the requirements of section 14212(b) of the 

2008 Farm Bill. On May 29, 2012, 92 days after the date on the 

congressional notifications FSA provided us, the Secretary announced 

the closure of 125 FSA offices. Six offices that had been proposed for 

closure were not closed because, based on concerns raised during the 

public meetings, FSA recalculated the distance between these offices and 

the next closest FSA offices and found the distance was more than 20 

miles.

 

4

A beginning farmer or rancher is one who (1) has not operated a farm or ranch, or who 

has operated a farm or ranch for not more than 10 consecutive years and (2) will 

materially and substantially participate in the operation of the farm or ranch.

FSA Held Public Meetings 

and Accepted Comments

FSA Approved Its Office 

Closures More Than 90 

Days after Sending 

Notices to Congressional 

Committees and Members
Appendix III: Section 14212(b) of the Food, 

Conservation, and Energy Act of 2008 and the 

Farm Service Agency’s Office Closures 

Initiated in Fiscal Year 2012

Page 56 GAO-14-288 Department of Agriculture

FSA closed 125 offices between June 1, 2012, and March 1, 2013. FSA 

officials told us that the timing of office closures was based on information 

that state executive directors provided in surveys on when the offices 

could notify employees, schedule physical moves, and take other 

necessary actions to close. Of the 125 offices closed, 98 offices had two 

or fewer permanent full-time employees and were located less than 20 

miles from another FSA office.5 However, we found that, in two instances, 

FSA used an office that was slated to be closed as the nearest office in 

calculating the distance rather than an office that would remain open.

Specifically, FSA identified the Shelby County, Texas, and San Augustine 

County, Texas, offices as being less than 20 miles from each other, and 

then closed both. As a result, the nearest open FSA office, according to 

our analysis, is in Nacogdoches County, Texas, over 30 miles from each 

of these offices. FSA officials told us that these offices were closed 

because both offices had one or two employees and were located less 

than 20 miles from another office.6 The other 27 closed offices had no 

permanent full-time employees and were located more than 20 miles from 

another FSA office.7 However, the offices located less than 20 miles from 

another office were not closed before the offices located more than 20 

miles from another office were closed. We did not assess whether FSA 

complied with section 14212(b).

 

5

FSA officials told us that the agency closed all offices that had two or fewer employees 

and that were less than 20 miles from another FSA field office. We were not able to 

independently verify this.

6

Our analysis also found that one to three other offices may have been slightly over 20 

miles from the next closest office depending on the calculation used; however, these 

differences are likely explained by variations in the methods used by FSA and the 

methods used in our analysis.

7

According to FSA officials, offices without any employees could be the result of 

vacancies not being backfilled due to staffing constraints. FSA employees from other 

locations had to travel to these offices weekly to provide service.

FSA Closed Offices 

between June 2012 and 

March 2013
Appendix IV: Comments from the Department 

of Agriculture

Page 57 GAO-14-288 Department of Agriculture

Appendix IV: Comments from the 

Department of Agriculture
Appendix IV: Comments from the Department 

of Agriculture

Page 58 GAO-14-288 Department of Agriculture
Appendix V: GAO Contact and Staff 

Acknowledgments

Page 59 GAO-14-288 Department of Agriculture

Anne-Marie Fennell (202) 512-3841, or fennella@gao.gov

In addition to the individual named above, Thomas M. Cook (Assistant 

Director), Karen Jones (Assistant Director), Cheryl Arvidson, Candace 

Carpenter, David Garcia, Armetha Liles, Rebecca Shea, Jeanette Soares, 

and Ruth Solomon made key contributions to this report.

Appendix V: GAO Contact and Staff 

Acknowledgments

GAO Contact

Staff 

Acknowledgments

(361444)
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